The British Electric Bicycle Association (BEBA), representing ten UK electric bike companies, just released this statement, adding their voice to the ongoing industry debate about the future regulation of electric bikes and related vehicles. Their release follows verbatim:
BEBA press release
BEBA has been monitoring the recent opinions of ETRA and various other bicycle groups regarding the proposed changes to the Motor Cycles Framework Regulation COM (2010) 542 by the IMCO Commission of the European Parliament with great interest.
BEBA represents the interests of members who predominantly specialise in the manufacture and distribution of electrically assisted bicycles. We believe we have a balanced and complete understanding of the regulations and rules governing the use of electric bicycles in both the UK and Europe. Because our members are predominantly electric bike specialists we probably have the best understanding of the needs and wants of the UK electric bicycle buying public.
It is our opinion that the changes proposed by ETRA are not only good for the industry but will also encourage an increasing number of people away from their cars and vans and onto electrically assisted pedal cycles and tricycles. Which is beneficial to the whole cycle industry. To try and create differences between what is acceptable in the UK and in Europe can only be harmful, driving up prices in the UK and perpetuating the confusion between what is acceptable in the UK and the rest of Europe.
It is important to understand that the proposed changes to the wattage of the motor will not affect acceleration or top speed. Through electronic regulation bikes will still have to be within the parameters of the existing European standard EN15194. Higher wattage motors may increase the weight of a bicycle but by no more than 1kg. Although the detail is not clear it seems that most manufacturers will have to reduce the weight of their bicycles to meet the new 25kg maximum weight limit if they want to retain a full throttle. Consequently any extra power will simply be used to enable electrically assisted bicycles to negotiate steeper inclines or carry heavier loads. This in turn will allow older people, those with health issues and some delivery services such as the post office to use electrically assisted bicycles instead of conventional vehicles associated with road congestion and pollution.
The issue of "twist and go" throttles in our opinion is reasonably straightforward. They are legally fitted to more than 80% of all electric bikes currently in use in the UK without any issues as far as we can ascertain. We understand from recent consultation with electric bike riders in the UK that the twist and go throttle is considered a huge benefit in terms of safety and usability.
In the experience of riders in the UK the throttle is an invaluable asset for the riders safety in the following real world conditions:
- Stability. When riding on sand, snow or ice, a throttle provides enhanced stability. A rider can stop pedalling and lower their centre of gravity whilst still slowly moving forward.
- Keeping clear of heavy traffic. Riders find they are able to ride much closer to the kerb when forced to do so by other traffic, the danger of catching a pedal on the kerb is reduced to becoming almost insignificant.
- Faster and safer starts. The use of a throttle will help get a bike moving quickly, reducing wobble during take off, particularly when at the front of a queue at traffic lights, on hills or crossing busy roads. Being able to simply twist a throttle to add boost is far safer than trying to stand up on the pedals to get the bike moving to a safe speed.
- Speed control. Riders can move slowly yet steadily on busy cycle paths and avoid situations where they are in too high a gear and can't easily maintain forward motion.
- Speed boost. Being able to accelerate at a moments notice is valuable for getting out of the way of motorists in dangerous situations.
We must stress that we do not approve of electric bikes exceeding the 15.5mph limit being used on the public highway or cycle paths.
Whilst most non-electric riders could live without a throttle there does not seem to be any good reason to remove its use from future electric bicycles.
From a recent study of electric bikes owners preferences we have discovered that of those who have the benefit of twist and go throttle in the UK;
7% never use the throttle.
24% use throttle on start up to help get going and for safety reasons.
28% use the throttle occasionally to rest legs/heart/lungs.
41% always use the throttle.
Electric bicycles are not normally associated with young and fit individuals who ride a pedal cycle for pleasure or a few miles to and from their place of work. They are predominantly purchased by those who would not normally consider a bicycle at all and others who appreciate assistance on a long commute and would prefer to arrive at their destination without needing a shower.
Electric bicycles remain a key growth area in the UK cycle market however manufacturers, distributors and cycling organisations must take note of the consumers needs.
BEBA are fully supportive of making cycling more available to everyone, including less abled riders, offering them the freedom that so many of us already take for granted. We strongly believe that the proposed changes to the current legislation will further open cycling to all.
British Electric Bicycle Association
“Although the detail is not clear it seems that most manufacturers will have to reduce the weight of their bicycles to meet the new 25kg maximum weight limit if they want to retain a full throttle.”
Kingfish wrote:The part that amused me was:“Although the detail is not clear it seems that most manufacturers will have to reduce the weight of their bicycles to meet the new 25kg maximum weight limit if they want to retain a full throttle.”
25 kg = 55 pounds. Take any MtB, add a 14-pound motor to it, and you’ll have maybe 11 pounds left over for batteries? That’s about 20Ah @ 36V. Not very useful range there Mr. Nanny-State.
I'm glad I don't have every aspect of my life overseen by a bunch of bureaucrats in Brussels.
my throttle-off, motor-freewheeling tricycle does over thirty downhill a 4% 1/4 mile hill.veloman wrote:Good gawd. What use is a motor if you are limited to 12 or 15mph? (yeah, 15mph up a big hill is good, but it's crawling on the flats).
Oh wait, so the e-moped class allows you to air pedal at 27mph..... that's not too bad.
Does it say anything about downhills or tailwinds? My road bike will coast at 25mph down shallow hills.
cruiserbikeman wrote:If you were paying for tags title and insurance on ebikes they wouldn't mind how fast you were riding. Since we're not, then we can't enjoy traveling at the speeds that automobiles can.
veloman wrote:cruiserbikeman wrote:If you were paying for tags title and insurance on ebikes they wouldn't mind how fast you were riding. Since we're not, then we can't enjoy traveling at the speeds that automobiles can.
But they design a road for only full auto speed. If it was 100% safe to go 20mph, then they have an argument. But it's not. Pedestrians don't pay for tags, title, insurance, and they get their own safe facility almost everywhere. Just saying....
But I do see your point.
The European Parliament is about to vote the review of the type-approval. In a dramatic appeal to all MEP’s, ETRA urges them not to vote article 2.2(g) of the compromise text. According to ETRA, this article is an open invitation for electric bicycle manufacturers to circumvent the type-approval procedure. ETRA issues a stark warning that article 2.2(g) will produce serious safety risks and put lives at risk.
The European Parliament and Council have reached a compromise on the Proposal for Regulation on the approval and market surveillance of two- or three-wheel vehicles and quadricycles. This compromise still needs to be formally debated and voted in Plenary. That is scheduled for Monday 19 and Tuesday 20 November.
In the run-up to the Plenary session, ETRA has made a dramatic appeal to all Members of the European Parliament not to vote article 2.2(g) of the proposal. That article stipulates that the Regulation does not apply to vehicles primarily intended for off-road use and designed to travel on unpaved surfaces.
According to ETRA, this article is a permit for manufacturers of electric bicycles to circumvent type-approval and to put vehicles on the market with optimum functional danger levels rather than safety levels. ETRA also calls the article a permit for manufacturers to put vehicles on the market for irresponsible consumers who are only interested in speed and power output.
ETRA Secretary General Annick Roetynck further explains: “Manufacturers can very easily declare their electric bicycles vehicles primarily intended for off-road use and designed to travel on unpaved surfaces, since there are no criteria whatsoever set for labelling a vehicle as such.” Designed to travel on unpaved surfaces has in this context no meaning whatsoever because even if they are designed for that purpose, there is no rule against use on public roads. For comparison, many a mountain bike is used on public roads though it is primarily intended for off-road use and designed to travel on unpaved surfaces.
Annick Roetynck continues: “If a manufacturer labels his electric bicycle as a vehicle primarily intended for off road use and designed to travel on unpaved surfaces then the vehicle is out of the type-approval and there are no other technical rules applying. There is only the General Product Safety Directive which obliges the manufacturer to put a safe product on the market. Furthermore, the owner of the above vehicle will be allowed to use the vehicle without any other obligations, i.e. helmet, insurance, driving licence, age limit, … There is no speed limit by construction set for his vehicle, nor a motor output limit.”
ETRA finds it very difficult to see the consistency in Commission, Council and Parliament’s position with reference to electric bicycles in this legislative dossier. One of ETRA’s requests to the European authorities was to exclude pedal assisted electric bicycles with assistance up to 25 km/h from the type-approval, irrespective of their motor output level. The motor output has no effect on the speed since the motor automatically stops at 25 km/h, irrespective of that motor output. IMCO adopted the relevant amendment but it was subsequently deleted in the trialogue negotiations because Commission and Council feared the amendment would create a safety risk. In parallel, with article 2.2(g) Commission and Council proposed to exclude a category of vehicles, including electric bicycles, without any specification of speed and motor output limit!
ETRA is unequivocal about article 2.2(g): absolutely inconsistent, dangerous and irresponsible.
Warnings for this same article were issued by the motorcycle community. As a result, enduro, trial and heavy duty quads were explicitly re-included in the compromise text.
ETRA has been warning Commission, Council and Parliament about the fact that this article will be abused to avoid the type-approval procedure for electric bicycles since 2009 and has proposed an amendment to overcome the problem, but that was eventually totally ignored.
According to ETRA it is very likely that manufacturers of electric bicycles will use the way out of type-approval offered to them by article 2.2(g) because type-approval is an extremely complicated, expensive and inappropriate regulation since it is designed for conventional mopeds and motorcycles, not for electric bicycles.
The Commission and Council have systematically ignored ETRA’s proposals aimed at developing appropriate and effective regulations for electric bicycles. Originally, the IMCO Committee agreed with ETRA’s proposals and included them through the necessary amendments in the van de Camp report. However all these amendments were deleted again from the compromise text agreed between Council, Commission and Parliament, the text to be discussed and voted in the next Plenary Session.
In a reaction on this compromise to Rapporteur van de Camp, his Shadow Rapporteurs and to the IMCO coordinators ETRA stated: “We are disillusioned beyond words to find that all amendments for the benefit of electric bicycles have been deleted from the compromise text. This is no less than dramatic for the electric bicycle sector in the European Union, since it means that a type-approval procedure, which is totally inappropriate and ineffective for electric bicycles, will continue to apply for at least another decade! This will very seriously obstruct the development of the European electric bicycle market.”
ETRA was informally told that the amendments for the benefit of electric bicycles were sacrificed for the sake of reaching a compromise. Commission and Council continued to oppose the amendments because they had concerns about the resulting safety aspects. ETRA’s response to this: “We deeply regret that Council, Commission and Parliament have refused to accept our in-depth and repeated clarifications and reassurances on this issue. Instead, the incorrect, unfounded and inflammatory argumentation of the opponents to our proposals has prevailed. Ironically enough, the compromise text turns out no less than dramatic for the electric bicycle business because with article 2.2(g) it will without any doubt produce very serious safety risks. The fact that none of the opponents to our proposals have taken this risk into consideration nor acted upon, proves in our view their lack of understanding of the whole type-approval issue with reference to electric bicycles.”
ETRA firmly believes that precisely the fact that the future type-approval procedure is not appropriate and effective for electric bicycles creates the risk that manufacturers will avoid the procedure on the basis of Article 2.2(g).
It is still possible to table amendments before Plenary, provided these amendments are supported by at least thirty MEPs or one political group. That is why ETRA has formulated two amendments aimed at remedying the problems resulting from the compromise text for electric bicycles. All MEPs have been urged to support the amendments.
The new type-approval procedure for electric bicycles will have to be implemented before the end of 2016. This leaves ETRA with 4 more years to obtain better regulations for electric bicycles should this ultimate effort before the vote in Plenary fail.
gensem wrote:When i was fit I was able to keep 32-35km/h with a regular mtb using 1.8 street tires...
Whatever..... it's not that relevant to the general issue.SamTexas wrote:gensem wrote:When i was fit I was able to keep 32-35km/h with a regular mtb using 1.8 street tires...
For how long? 60 minutes? 30 minutes? 15, 5 or 3?
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