AODA Alliance June 22, 2023 Supplemental Brief to the Infrastructure and Environment Committee of the City of Toronto

Accessibility for Ontarians with Disabilities Act Alliance Update

United for a Barrier-Free Ontario for All People with Disabilities

Don’t Allow E-scooters in Toronto – Don’t Conduct an Experiment on Non-Consenting Vulnerable People with Disabilities, Seniors and Others


AODA Alliance Supplemental Brief to the Infrastructure and Environment Committee of the City of Toronto


June 22, 2023




This brief supplements the June 1, 2023 AODA Alliance brief that we submitted to the Toronto Infrastructure and Environment Committee. It explains why Toronto should not re-open its ban on e-scooters.


As our June 1, 2023 brief shows, e-scooters threaten both personal safety and accessibility for vulnerable people with disabilities, seniors and others. Toronto is in many ways getting less accessible for us. Don’t make it worse.


On June 5, 2023, the Infrastructure and Environment Committee e-scooters agenda item was adjourned. This came as a relief to people with disabilities and seniors. We don’t want to, again, have to do battle against the well-funded e-scooter corporate lobbyists, after a harrowing battle just two years ago.


However, that relief was short lived. A new motion on e-scooters has been scheduled for the June 28, 2023 meeting of the Infrastructure and Environment Committee. We here supplement our June 1, 2023 brief, by offering focused and specific feedback on that motion, presented by Councillor Dianne Saxe.


 Our Bottom Line



We respectfully object to this entire motion. We do so, respecting and appreciating that Councillor Saxe has made a real effort to incorporate in it a number of the serious disability/seniors concerns about e-scooters.


We call on the Infrastructure and Environment Committee not to re-open Toronto’s ban on e-scooters. Do not conduct a pilot project with e-scooters in Toronto. It would amount to an experiment on us, over our objection, and endangering our safety and accessibility in the process. We ask the Infrastructure and Environment Committee to instead devote time to making Toronto’s infrastructure and environment more accessible for people with disabilities, and not to creating a new accessibility barrier in the form of e-scooters.


No evidence has been presented that controverts the impressive and detailed 2020 and 2021 reports by City staff on e-scooters. City staff are not recommending that the Infrastructure and Environment Committee re-open this issue so soon after it was exhaustively explored by City staff and City Council. This appears to be a result of the non-stop efforts of the e-scooter corporate lobbyists. We need the Infrastructure and Environment Committee to stand up to those corporate lobbyists and to stand up for people with disabilities.


The fact that some cities in Ontario have already allowed e-scooters does not disprove our concerns. We regret that those cities proceeded to allow e-scooters despite objections from the disability community. None of them disproved the detailed findings in the 2020 and 2021 Toronto City staff reports.


Recommendations Regarding Councillor Saxe’s Motion, if it is to Proceed Despite Our Objections to Re-Opening the Ban on E-Scooters


If, despite the preceding concerns, the Infrastructure and Environment Committee nevertheless decides to proceed with the motion proposed by Councillor Saxe, then we respectfully request several revisions to the motion. These all fit within the framework and intent of the motion.


  1. The introduction to the motion refers to objections to e-scooters that have been made by people with disabilities. It should be revised in each instance to include both people with disabilities and seniors.


  1. The introduction states:


“In 2021, Toronto chose not to partake in the pilot project, largely because of concerns raised by the disability community about e-scooters being ridden and littered on the sidewalk.”

This understates the disability-related concerns with e-scooters. The introduction should be revised to include the fact that serious concerns were also expressed by people with disabilities, seniors and others about e-scooters as a silent menace, ridden by unlicensed, unhelmeted, untrained and uninsured riders, whether on roads, at street crossings, or on other public places where pedestrians can walk, such as park paths and pedestrian/bike paths (e.g. the Kay Gardner Beltway Trail).


  1. The introduction states that e-scooters create no “pollution at point of use.” However, it should be revised to acknowledge that they create land fill. Their batteries, once used up, are also a form of harmful waste.


  1. The introduction should be revised to include the danger that e-scooters can create to safety and property, because their batteries can catch fire.


  1. The introduction states:


“As well as many other cities around the world, several Ontario municipalities permit the use of e-scooters, including Ottawa, Durham (By-law 23-2022) and Brampton.”


It should be revised to state that some major cities that have allowed e-scooters have subsequently withdrawn this, such as Montreal and Paris France. As well, where e-scooters are allowed, they are the subject of major objections by pedestrians.


  1. The recommendations strongly imply that there should be an e-scooter pilot in Toronto, and that the requested staff report focuses on what terms and conditions should apply. We respectfully propose that this wrongly puts the cart before the horse. The Infrastructure and Environment Committee should not now decide, directly or indirectly, that there should be an e-scooter pilot. At most, it should ask for the advice of City staff on whether there should be such a pilot, and if so, on what terms and for what purpose.


If there is to be any staff report requested at all, Recommendation 1 should ask for a report on whether there has been a substantial improvement since the City staff’s 2020 and 2021 reports on e-scooters, and whether City staff recommend that Toronto conduct a pilot with e-scooters, and if so, under what conditions.


Such a direction would unequivocally leave City staff with a clear option, if they so conclude, that no pilot can safely be conducted without creating new disability accessibility barriers and without endangering public safety.

  1. If, despite our objections, a City staff report is to be directed on the issue of Toronto possibly conducting a “pilot” with e-scooters, it should direct that if City staff do recommend a pilot, they should specify what issues the pilot is to answer, explore or test for. It is not appropriate to simply conduct a pilot or study, without specifying in advance what question or issue the pilot is meant to answer.


  1. The motion’s timeline for City staff to report back, February 24, 2024, is too short. There should be sufficient time for proper research and consultation, including community involvement. The report back should be no earlier than June 2024.


This should, for example, include requiring Toronto City staff to hold open, disability-accessible town halls with members of the disability and senior communities. It is not sufficient to invite the public to submit written input on some cold website. Inviting written input over the internet creates serious barriers to participation for many.


  1. It is good that the motion requires City staff to consult with the Toronto Accessibility Advisory Committee (TAAC). However, this is far from sufficient. The TAAC is not elected by the broad disability community. Dedicated TAAC members have lots to offer, but they are not our representatives. Moreover, TAAC members are volunteers, holding meetings with strict time limits on deputations. We appreciate them volunteering their time. However, the City should not use them as a proxy for the City staff conducting the needed fulsome consultation.


If there is to be a City staff report requested, City staff should also be required to directly get input from and consult with the broader disability community and the seniors community, as well, of course, as the pedestrian community. Therefore, the motion should be revised to explicitly require City staff to consult directly with the disability community, senior community and the pedestrian community.


  1. The motion’s Recommendation 1 should be revised to require consultation with the Toronto Medical Officer of Health and Toronto Public Health, and with law enforcement including Toronto Police Services and bylaw enforcement officials.


  1. It is Good that Recommendation 2 includes:


“E. The pilot project would collect detailed, up to date data on all injuries and collisions.”


However, that incorrectly pre-supposes that there are already in place effective ways for City staff to effectively collect this comprehensive data. This data collection should not rely on victims of e-scooter injuries to file complaints or report injuries. Many victims will not know about the City’s attempt to collect data or will not want to go to the effort of doing so after already suffering an injury caused by the City deciding to hold an e-scooter pilot. Moreover, we understand that there is no effective system now in place for City staff to be able to collect comprehensive needed data on e-scooter-related injuries.


We therefore recommend that the motion be revised to direct City staff to report on:

  • What measures need to be in place to enable the City to effectively gather comprehensive reliable information on e-scooter-related injuries from hospitals, doctors’ offices, as well as offices of other front-line health providers like physiotherapists.
  • Whether those measures are now in place.
  • If they are not in place, what must be done and at what cost to the taxpayer to put them in place, including who has authority to direct that they be put in place, and how long it would take to get them established.


  1. E-scooters are known to cause personal injuries and deaths. We earlier gathered and publicized 25 news articles giving examples of this.


Sadly, there have been additional e-scooter tragedies recently reported closer to home:




Recommendation 2 should be revised to require City staff to report on the personal injuries and deaths that e-scooters cause, in cities around the world where e-scooters have been permitted. This should not be limited to North America, as the motion elsewhere now provides. There is no good reason for arbitrarily excluding the experiences in Europe, New Zealand, Israel or elsewhere.


  1. Recommendation 2 should be revised to direct City staff to study the impact of e-scooters on urban blight, such as clutter of rental e-scooters in downtown and heavily congested areas.


  1. Recommendation 3 now requires that City staff study and report on the following, among other things:


“E. how other North American cities manage the risks that e-scooters pose to pedestrians and other vulnerable road users.”


Here again, this should be revised to include any cities around the world, and not only those in North America.