local law says that you need a means to cause your rear tire to skid. a fixed gear without brakes thus qualifies.

the thing with riding brakeless is that it's a totally different type of riding. you can't expect to take your brakes off and behave the same way on the road as you would if you had brakes. so yes, it involves riding slower in certain situations, slowing down much sooner than you would if you had brakes, descending hills at an rpm which allows you to hop skid in case of emergency, etc.

furthermore, to be a proficient brakeless rider, you have to have skills that you wouldn't have otherwise. you have to know how to slow down by carving, how to lock your rear wheel or slow down the front wheel if your chain snaps, how to turn the bike sideways in case of emergency, etc. until you learn some of these things, you ride slower and choose your routes.

so ask yourself why you ride fixed... i mean, gears are much better because you can climb hills easier. and coasting is better because you can go fast on the downhills. riding fixed is much more dangerous. if you snap your chain and your wheel gets locked at high speed, you're screwed. if you enter a turn at high speed and your pedal smacks into the ground, you're toast. if your pants or shoelaces get caught in your chain, you're on the ground. yet people still ride fixed gear daily. are they crazy?

i think brakeless is the same way. it's riskier, but it has its upsides. it offers a much more pure ride, you feel much more connected to the bike and road, you remove even more parts that need maintenance/adjustments/replacement off the bike (something that makes fixed gear riding so attractive to begin with) and it makes you much more aware of your surroundings.