common position review

COMMON POSITION

on Bucharest Municipality proposal to regulate the e-scooters

renting services

Lime, Bolt and Splash

Safety is our primary concern and we understand the Municipality of

Bucharest’s need to enhance it. To this end, we are open to engage
in a constructive discussion with the authorities and find common
solutions which would further micro mobility in Bucharest.

Please find below our comments and suggestions to your proposal.

Licensing. Potential very high fees for electric scooter licensing or

taxation measures may ultimately hinder the development of easily
accessible and affordable micro-mobility in the cities, thus
contradicting the objective of integrated public transport systems
and financially burden the end user. E-scooters are key to low-
emission transport growth, reducing traffic congestion and air
pollution. The fee level requested by Bucharest City Hall should take
into account the revenue generated by e-scooters. Major markets in
the EU (Germany, Poland, Czech Republic, Hungary) do not charge
fees while those applying a fee (France) charge 50€ and 65€ per
scooter per year based on fleet size, similar to the proposed values,
but considering a context of notably higher income of citizens.

It is not clear from the proposal the extent of the licensing process.
According to article 12 of GEO 13/2020, e-scooters are exempted
from mandatory registration.

License quota. E-scooters providers operate on a thin margin.

Volume is a key driver of both profitability and users experience.
Data analysis have shown that reliability can only be driven by a
large enough fleet which would ensure finding e-scooters within
500 meters reach. Not filling these prerequisites would lead to a
poor user experience and not promote electric scooters as a fast,
available, and reliable mode of transport in the city. Access to a fleet
up to 2.500 scooters per operator would ensure reliability of supply
for users and therefore a higher conversion towards micro mobility
from other means of transportation.

Limiting activity time frame. Based on our international experience

both in Bucharest and elsewhere, operations are safe year-round.
To enhance a safe riding experience, we consider that education of
riders and information campaigns can better equip the users during
wintertime. Upholding trips in winter is key in being paid back for
fees.

Liability insurance. Risk and liability of electric scooter operations

are best addressed through rider education. Educating is a more
efficient way to reduce liability risks than the implementation of
dedicated insurance measures (civil and theft) which ultimately
would hinder the dynamic development of these means of
transport.

Speed limit. The proposed 20 km/h goes against the current

legislation (25 km/h) provisioned in article 6 of the GEO 13/2020. It
is also more restrictive than in most of the markets in the EU. E-
scooters will become an inefficient alternative to cars while price per
trip (charged per minute) will increase.

Speed limit in parks. Introducing pedestrian speed for electric

scooters is dangerous because it makes the device unstable and
hard to steer which can have a direct impact on the safety of both
rider and pedestrians. In any case, the maximum speed limit for
electric scooters should be equivalent to the one for bicycles. A
speed limit of 10km/h would render scooters equivalent to fast
running.

GPS location. Sharing this type of data with the Municipality raises
GDPR concerns and it should be revised accordingly.

Lock-tosystem. Such a system is redundant as our e-scooters are

equipped with GPS monitoring system and an electronic lock. It
goes against the principle of us being responsible for our own
property and has limited to no impact on vandalism. It is also
counter intuitive for users which are now used to unlock the e-
scooters directly from the app. Based on our international
experience, these solutions do nothing to support their intended
purpose and simply add costs while citizens unwillingly end out
locking scooters.

Parking. Fixed parking spaces are extremely detrimental to micro

mobility, causing a massive drop in utilization of assets. We operate
dynamically based on machine-learning algorithms meant to serve
demand where it exists versus using human logic to define and build
parking stations at notable cost. Current device location technology
does not offer the level of granularity which allows to determine the
exact location whether the scooter is on a sidewalk or not. Any
move towards fixed parking has showcased massive drop in
utilization (up to 50%) for competitors using these methods,
ultimately showcasing that the dock-less mondel should be the
standard for the industry. Other measures such as scooter users’
education should be undertaken to efficiently implement such
provision.

Based on its market experience, we believe that a 6-hour time frame

for relocation of all deployed scooters may often be unrealistic given
the scope of operation and creates unsustainable cost, rendering
operations unprofitable.

POZIȚIE COMUNĂ

privind propunerea de regulament pentru circulația trotinetelor în

Municipiul București

Lime Bolt Splash

Siguranța rămâne principala preocupare pentru noi. De aceea

înțelegem interesul Primăriei Municipiului București

Safety is our primary concern and we understand the Municipality of

Bucharest’s need to enhance it. To this end, we are open to engage
in a constructive discussion with the authorities and find common
solutions which would further micro mobility in Bucharest.

Please find below our comments and suggestions to your proposal.

Despre Lime

Lime face parte din viaţa urbană a Europei. Din Paris la Varşovia, de
la Praga la București, reinventăm modalitatea de deplasare în oraşe.
Aducem oamenii mai aproape de ceea ce îi înconjoară, într-un mod
mai durabil, mai incluziv şi mai accesibil. Printr-o colaborare strânsă
cu comunităţile şi autorităţile locale din Europa, construim o nouă
cultură a mobilităţii partajate şi oferim soluţii provocărilor vieţii
urbane. Suntem prezenţi în peste 50 de oraşe din 20 ţări europene.
Pentru informaţii suplimentare, accesaţi pagina: https://www.li.me/