European regulations

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Arbol   100 W

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European regulations

Post by Arbol » Aug 10 2013 2:33pm

I live in Europe. Here, we have a limit of 250w of power. Also, one could not use the motor unless the biker pedals.

However, rules seems to be broken by some brands. For example, the Spanish brand BH offers 350W motors, but "limited to" 250W. I have not been able to find how do they limit the power. Also, several brands offer a "6 km/h" button, which allows the motor to work without pedaling up to 6km/h.

Not being a lawyer, these two characteristics seem at odds with European regulations. But those brands have a reputation, so if they do that, it means it is somewhat legal.

My question is as follows:

Is it possible to have a big motor (with big defined as more than 250W) but limiting it to 250W for open roads? This limitation could be done for example with a Cycle Analyst, having a Legal or Eco program defining amperage to limit power to legal figures. And then there would be another, unlimited program, not to be used under open roads.

I would like to ask the opinion of people with some experience on this subject, since this issue seems highly non-intuitive (like the 350W or the 6km/h issues). Common sense does not seem to work well here. Explicit rule of law is what is needed.

I am not arguing at all to use this as a trick to use big amounts of power on open roads, by stealth. At least in my city, more than 25km/h is a serious risk, and 250W is probably logical. I am talking for example to go out on a weekend to the hills, out of tarmac, and be able to have higher power.

Opinions?

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Re: European regulations

Post by bowlofsalad » Aug 10 2013 3:08pm

Why not do things stealthy? Are there check points for vehicles? Makes you wonder why so many places seem so constrictive to ebikes. Personally, the idea that there is a watt or horse power limit seems insanely draconian and illegal. Create a speed limit for areas, fine, but the idea of street legal for an ebike seems ridiculous.

Anyway, nobody is going to know if you have more than 250w unless you are raging up a hill nearly hitting people as you do without pedaling. I'd just setup a speed limit with your CA and get whatever wattage you'd be happy with. You are about as likely to meet an cop that is an expert on ebikes and was able to tell how much output you could use, and care, as you are to dance with a moose on an island made out of cheesecake.

I don't know if you own an ebike, but you can program the controller to limit the throttle to various percentages with a three speed switch. So if on your bike 6km/h was around 16% of your throttle, you could set that to in your controller as speed one, flip to that with your three speed switch and just keep it at 100% throttle which would be like turning it to 16% throttle. Then, program speed two to something faster, and maybe speed three as wide open throttle (100%) relying solely on the CA as a limit.

http://ebike.ca/simulator/ I don't know if you have seen this before, but play around with it, it might help you understand some things.

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Re: European regulations

Post by Drunkskunk » Aug 10 2013 3:17pm

Depending on which controller you chose, there is an option for a 3 position switch. you can program the controller to have a certian limit in each position, alwoing a "totaly Legal" setting, a "Mostly legal, in the right context" and a "Go To Jail!" setting.. Err, a "This is for off road only" setting.

As for motor rating, that is somewhat ambigious. A motor will have a duty rating, but what most laws specify is the motors output. That output is almost entirly dependant on the controller, not the motor. a 250 watt motor might put out 1000 watts, while a 500 watt motor might only put out 750 watts, all depending on the contrtoller's settings. A 500 watt duty rated motor will have the same output as a 250 watt if they both use the same setting of the controller. The important part of that is the motor's rating has little to do with the motor's output.

So if you want 250 watts output, pick a motor what won't melt under the conditions you plan to subect it to, then tune the controller for 250 watts or whatever is legal, and call it a 250 watt system. Then to comply with the law, which doesn't understand how electric motors actualy work, stick a 250 watt sticker on the motor and call it legal. mostly. You will have met the spirit of the law, while the actual letter of the law might be impossable for any motor to meet.
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Re: European regulations

Post by Arbol » Aug 10 2013 3:22pm

Thanks for your reply.

My concern is not so much breaking the law per se, but potential liability in case of an accident. I use my bike in Barcelona, and despite having lots of km with bike lanes, there are always problems: pedestrians crossing by, etc. Many people do not even know there are lanes for bikes. In fact, many people walk along the bike lanes because in their inner minds, they believe those white strips on the floor are for them to walk along them.

Even, it could be it is not my fault, but if somebody looks at the motor and sees power above 250W, that could create an issue against me. A normal person could not know, but maybe an insurer expert could know. I know some people could believe I am too alarming, but I believe it makes sense to think about those issues.

Instead, I could not care less if I am breaking the law with excess power if I am in the middle of the hills, since they are almost always empty. If I have an accident, it will be my fault and I will suffer the consequences, but not anybody else.

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Re: European regulations

Post by Lebowski » Aug 10 2013 4:02pm

The bosch systemwhich is legally sold in europe is more than 600 watt. The law is that the long term average power should not be more than 250 watt, but it doesn't say anything about short power bursts. This is why the bosch is over 600, the average is 250 though. This is why the bozch system feels so powerfull, going uphill it delivers a lot more than 250...

My own personal bike delivers 1 KW peak going uphill but is limited to 25 km per hour... on an average day commuting to work i use 160wh over 1.5 hours, so according to the european way of looking at things its only a 110W system

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Re: European regulations

Post by teklektik » Aug 10 2013 5:44pm

The Cycle Analyst V3 supports PAS and can limit speed, watts, and Amps. The V3 PAS mode can be configured to comply with various EU regulations by requiring pedaling for assist, limiting the maximum assisted speed, the maximum watts assistance, and maximum speed for unassisted throttle. Some effort was made in the Spring to alter the PAS functionality to support users in non-US countries. The modes are described in section 6.5 of the V3 Guide. The V3 also provides up to three 'presets' so that you can have different configuration parameter setups readily available e.g. 'Legal', 'Unlimited', etc. These presets can be selected via the CA console or can be configured to be selected by an external switch e.g. a thumb switch, hidden switch, or keyswitch.

This strategy is in line with the BH 'limiting' approach to legality you mention above. The V3 can be added to just about any ebike to add PAS and these legal compliance features. Liability is a slippery slope, but this is an easy way to get 100% compliance that will withstand official testing should it come to that.
Last edited by teklektik on Aug 10 2013 6:05pm, edited 1 time in total.
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Re: European regulations

Post by bowlofsalad » Aug 10 2013 6:00pm

Arbol wrote:Thanks for your reply.

My concern is not so much breaking the law per se, but potential liability in case of an accident. I use my bike in Barcelona, and despite having lots of km with bike lanes, there are always problems: pedestrians crossing by, etc. Many people do not even know there are lanes for bikes. In fact, many people walk along the bike lanes because in their inner minds, they believe those white strips on the floor are for them to walk along them.

Even, it could be it is not my fault, but if somebody looks at the motor and sees power above 250W, that could create an issue against me. A normal person could not know, but maybe an insurer expert could know. I know some people could believe I am too alarming, but I believe it makes sense to think about those issues.

Instead, I could not care less if I am breaking the law with excess power if I am in the middle of the hills, since they are almost always empty. If I have an accident, it will be my fault and I will suffer the consequences, but not anybody else.
I empathize and understand your frame of view, but do they look at a cars horse power as a means to pick out the guilty party in a car accident? I surely hope not. If your city doesn't mark the bike lane as a bike lane, perhaps either you can stencil it yourself or inform them of this error and your frame of mind concerning the chain of events involving people often assuming that lane is a sidewalk. I think the something you might strongly consider is a having a bell and using it, not having a bell and hitting someone as you silently biked up behind them on an ebike at any speed sounds far worse than having a mildly more powerful ebike kit. My last suggestion is to pass with extreme caution, I slow way down when passing a person who is walking and pass them as widely as I can without putting myself at risk. If you cannot pass them without putting yourself at great risk, DON'T TAKE THE RISK! Don't just try and blow past them at full speed with inches to spare, that would be a real asshole move, don't toss yourself across a traffic filled lane, that'd be a foolish act. If you have to stop and walk past them, use that time to try to educate them about their choices and how they effect them and those around them.

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Re: European regulations

Post by teklektik » Aug 10 2013 7:08pm

Oops - I missed you reference to the CA in the original post (how?), so apologies for the unnecessary V3 pitch. :)

I sort of jumped to the V3 recommendation based on the tacit assumption that you are 'likely' to be in a better position if your vehicle is compliant and that in itself appears easily achievable in the manner being followed by commercial vendors (BH as you called out). But - that's an uninformed layman's guess - from another country no less - and thus pretty worthless...
Arbol wrote:I would like to ask the opinion of people with some experience on this subject, since this issue seems highly non-intuitive (like the 350W or the 6km/h issues). Common sense does not seem to work well here. Explicit rule of law is what is needed.
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Re: European regulations

Post by Eskimo » Aug 10 2013 11:48pm

In my opinion "bowlofsalad" pretty much nailed it up there. About only people who might be interested of your power level are those lycra riders, and even then if you ride with them.
That 250W limit is insane. I could not do these rides what i do on saturdays with lycra riders with 250W, no way. That 250W just does not balance the 30kg weight of your E-bike well, even less above 25 km/h where it stops supporting. They go 30-35 km/h occasionally and i would not stand a chance with 30kg bike without assistance, and with some 24V-system my range would be bad.
Even then i kinda see your view, you live in Spain, where traffic culture and amount of population is a bit different story than it is here.
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Re: European regulations

Post by Arbol » Aug 11 2013 12:13am

bowlofsalad wrote:
I empathize and understand your frame of view, but do they look at a cars horse power as a means to pick out the guilty party in a car accident? I surely hope not. If your city doesn't mark the bike lane as a bike lane, perhaps either you can stencil it yourself or inform them of this error and your frame of mind concerning the chain of events involving people often assuming that lane is a sidewalk. I think the something you might strongly consider is a having a bell and using it, not having a bell and hitting someone as you silently biked up behind them on an ebike at any speed sounds far worse than having a mildly more powerful ebike kit. My last suggestion is to pass with extreme caution, I slow way down when passing a person who is walking and pass them as widely as I can without putting myself at risk. If you cannot pass them without putting yourself at great risk, DON'T TAKE THE RISK! Don't just try and blow past them at full speed with inches to spare, that would be a real asshole move, don't toss yourself across a traffic filled lane, that'd be a foolish act. If you have to stop and walk past them, use that time to try to educate them about their choices and how they effect them and those around them.
The problem about your comments is the way European cities are configured. In a normal trip, I would have to stop say twenty times, and educate twenty different people. Even more, many of them will be tourists, who do not know or care about bike lanes. Educating them is worthless.

I am skilled at avoiding problems many meters apart. I have a bell, and I use it very often. But oftentimes, unexpected actions happen, especially from old people or kids: even though I can pass them easily, they suddenly move in a direction (the direction of the bike lane) at the worst possible time. This does not happen very often, but if I have twenty problems per day, after say 250 days per year, a few times you have suddenly somebody going towards me when I do not have reaction time. Luckily, I have never had a serious problem (one day I had to fall from the bike to avoid a child; I got some bruises but nothing else). But if I had to stop against any potential problem, a bike would be useless, I would better walk. Bike lanes are improving over time, but it will take years until they are pedestrian-bullet proof.

For example, here there is a problem, since there is no separation between bikes and pedestrians:

Image

At the beach is better:

Image

And this is best:

Image

So, the limitation of 250w and 25km/h in European cities makes sense. In fact, possibly the speed limitation should be even lower (but the power limitation does not make sense, due to health problems, steep hills ...). But then, if you go to the hills, and if you are alone, why not being able to display full power?

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Re: European regulations

Post by bowlofsalad » Aug 11 2013 12:43am

Well, it is a dilemma, that is for certain. I am not sure what to tell you, this issue exists everywhere, I imagine, to some degree. I have crossed paths with many center of the path joggers with headphones on. You take the obvious risk you pointed out.

The only other option that you might be able to consider is alternative route plans. I know this isn't always an option, but riding on paths where lots of people are going to be walking might be easy to fix by simply riding somewhere else. If there are large packs of people frequenting an area that walk on paths that lack any sort of labels, it's probably a lost cause and not worth even trying to route. I am sure you are pretty familiar with where ever you ride, I think that is a very important idea, once in a while maybe consider trying a new path or direction just to see where it takes you and if it is a viable option for an alternate route to where you need to go. I have found many ways to get places this way, often resulting in a radically safer route. I don't know if there are many roads with full car sized shoulders where you are, but those roads aren't bad for riding on typically, assuming your tires are prepared for the garbage on the road.

I bet if you road around with a bike like this, people would hear you coming and look. Or maybe you should put a baseball card in your spokes.

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Re: European regulations

Post by d8veh » Aug 11 2013 4:43am

Arbol wrote:I live in Europe. Here, we have a limit of 250w of power.
That's not quite true. The standard that governs ebikes in Europe is EN15194. It restricts the motor to a maximum nominal continuous output rating of 250w. It doesn't limit the maximum power nor does it describe the method of rating, although there is an optional method of measuring power that can be used in the absence of a manufacturer's rating. So, manufacturers can use whatever method of rating they want for their motors as long as they don't over-rate them. The standard refers to a test method for rating motors that basically tests that the motor doesn't get too hot when run at its rated power, so if a 1000w motor is rated at 250w, it''ll pass the test.

My thoughts are that at first, the ebike and motor manufacturers didn't fully understand the actual requirements of the standard, but now they''re wising up how to get more power whilst still complying. Now we have lots of bikes certified to EN15194 that can climb steep hills fairly easily,and probably drawing around a kilowatt from the battery, but one thing you can't avoid is the 27.5 km/h speed limit, and you can't have power when you're not pedalling except there's a sort of amnesty on that in the UK.

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Re: European regulations

Post by greenspark » Aug 11 2013 6:04am

Arbol wrote:My concern is not so much breaking the law per se, but potential liability in case of an accident.
In New Zealand, the enforcement is to look at the sticker on the motor, UNTIL you get into an accident. Then they send your bike to an engineering company to test your motor. If it exceeds the legal limit, you are charged with various crimes, including driving a moped without proper registration, lights, horn, etc.

Thus your question is quite valid, and it is best answered by a lawyer who specialises in Euro-spec bicycle law). d8veh 's answer is worth confirming.

See http://www.hg.org/law-firms/bicycle-accident/spain.html . Looks like you even have a bicycle accident lawyer in Barcelona.

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Re: European regulations

Post by lollandster » Aug 11 2013 8:54am

You can find lots of information in the EN15194:2009 standard.
For the 6km/h limit the standard says the following
4.2.4.3.1 Requirements
EPAC can be equipped with a start up assistance mode up to 6 km/h designed speed or lower values as specified by the manufacturer. Unauthorized use shall be prevented.

This mode shall be activated by the voluntary and maintained action of the user either when riding without
pedalling or when the user is pushing the cycle.
The standard also defines a EPAC as
electrically power assisted cycle (EPAC)
cycle, equipped with pedals and an auxiliary electric motor, which cannot be propelled exclusively by means of this auxiliary electric motor

It applies to electrically power assisted cycles of a maximum continuous nominal power
of 0,25 kW, whose power is gradually reduced and finally stopped when the vehicle reaches
a speed of 25 km/h, or sooner, if the cyclist stops pedalling.
There is also a definition of the continuous rated power:
3.22
continuous rated power
continuous (or constant) output power specified by manufacturer, at which the motor reaches its thermal equilibrium at given ambient conditions

NOTE Thermal equilibrium: temperatures of motor parts do not vary more than 2K per hour.

In circumstance where the power is measured directly at the shaft of the electronic motor, the result of the measurement shall be decreased by 1,10 to consider the measurement uncertainty and then by 1,05 to include for example the transmission losses, unless the real values of these losses are determined.
What this means is that the motor is allowed to give more than 250w as long as it cannot do so for extended periods without overheating (overheating is defined as gaining more than 2K (I assume kelvin) per hour above ambient.)

Maximum speed is as follows:
4.2.6 Maximum speed for which the electric motor gives assistance

4.2.6.1 Requirements
The maximum speed for which the electric motor gives assistance may differ by ± 5% of the speed indicated on the label described within Clause 5 when determined according to the test method described in 4.2.6.2, from 25 km/h or lower values as specified by the manufacturer.

During a production conformity check, the maximum speed may differ by ± 10% from the above-mentioned
determined value.

4.2.6.2.1 Test conditions
a) The test may be performed either on a test track, a test bench or on a stand that keeps the motor driven
wheel free of the ground.

b) The speed-measuring device shall have the following characteristics:
 Accuracy: ± 2%
 Resolution: 0,1 km/h

c) The ambient temperature shall be between 5 °C and 35 °C.

d) Maximum wind speed: 3 m/s.

e) The battery shall be fully charged according to the manufacturer instructions.

4.2.6.2.2 Test procedure
Any appropriate method for checking for this requirement is acceptable; one solution is to measure the cut-off
speed, another being to measure the torque output. The following example describes the cut-off speed test.

a) Pre-condition the EPAC by running it for 5 min at 80% of the maximum assistance speed as declared by the manufacturer.

b) Record continuously the current and note the speed at which the current drops to a value equal to or less than “no load current point”.

c) Whilst pedalling, ride steadily to reach a speed equal to 1,25 times (if possible by design) the maximum assistance speed as declared by the manufacturer.

d) Verify the noted value in b) is equal to or less than the maximum speed declared by the manufacturer.
This basically means that when speed is above 27,5 km/h the current going to the motor should be less than the no load current (freewheeling motors will use some power to keep itself spinning without any of that power getting into the wheel, the current will therefor not be equal to zero)

This standard is targeted to manufactures and distributors of electric bikes. Most jurisdictions will give some leeway to self built bikes due to the lack of testing equipment and facilities. At the end of the day it is up to your judge to interpret the law.

I hope this helps clarify some of your questions.
I have no legal degree (only an engineering one) so take that into consideration when reading my answer.
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Re: European regulations

Post by Arbol » Aug 11 2013 9:31am

Very interesting, thank you.

First, when it is written:

electrically power assisted cycle (EPAC)
cycle, equipped with pedals and an auxiliary electric motor, which cannot be propelled exclusively by means of this auxiliary electric motor

It seems clear that the "auxiliary electric motor" is not the motor we understand as such, but the motor and the controller (at least).

Second, when it is written:

continuous rated power
continuous (or constant) output power specified by manufacturer, at which the motor reaches its thermal equilibrium at given ambient conditions

It seems clear then that apparently one cannot buy a motor independently from a controller, since the manufacturer must provide a figure for continuous rater power for the "auxiliary electric motor" (comprising the motor and the controller).

It seems (I am not a lawyer though) that the only condition is the 250w, 25km/h and PAS conditions must be satisfied. It is not specified how. If one has a 10kW motor, and with a Cycle Analyst power is limited to 250W, it seems it is fine.

But I would like more opinions, if possible.

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Re: European regulations

Post by lollandster » Aug 11 2013 11:44am

Arbol wrote:Very interesting, thank you.

First, when it is written:

electrically power assisted cycle (EPAC)
cycle, equipped with pedals and an auxiliary electric motor, which cannot be propelled exclusively by means of this auxiliary electric motor

It seems clear that the "auxiliary electric motor" is not the motor we understand as such, but the motor and the controller (at least).

Second, when it is written:

continuous rated power
continuous (or constant) output power specified by manufacturer, at which the motor reaches its thermal equilibrium at given ambient conditions

It seems clear then that apparently one cannot buy a motor independently from a controller, since the manufacturer must provide a figure for continuous rater power for the "auxiliary electric motor" (comprising the motor and the controller).

It seems (I am not a lawyer though) that the only condition is the 250w, 25km/h and PAS conditions must be satisfied. It is not specified how. If one has a 10kW motor, and with a Cycle Analyst power is limited to 250W, it seems it is fine.

But I would like more opinions, if possible.
The safest is probably to buy a kit from a distributor that clearly states that the kit follows the EN15194 standard (or that the motor is 250w according to EN6034-1). The good news is that a manufacturer can choose to run a 250w motor at way above 250w if he is willing to subject the motor to penitential overheating, maybe installing a temperature sensor that limits the power when it gets too hot.

If you don't have a motor that is tested (and you don't have the equipment to test it yourself) according to the EN6034-1 then the EN15194 section 4.2.7.2, maximum power measurement - Alternative method, describes an alternative method to rate your system that is easy to do yourself and is probably the only way to legally run a big motor with reduced power (A big motor being a motor that won't overheat if subjected to more than 250w).
4.2.7 Maximum power measurement
4.2.7.2 Alternative method

When the power is measured at the wheel, the result of the measurement is the reading value.
Annex D gives guidance on how to measure the power at the wheel.
Annex D:
D.3 Test procedure
Any appropriate method for checking for this requirement is acceptable.

a) Pre-condition the EPAC by running it for 5 min at 80% of the maximum assistance speed as declared by the manufacturer.

b) Stop the bicycle.

c) Note the time between the action start and the EPAC to travel 20 meters.

d) Verify the speed value is equal or less than the maximum speed declared by the manufacturer after 20 metres (D).

e) Verify the maximum continuous rated power at wheel is: P=m*((2*D^2)/T^3) with the time T which is the noted value in c).
The standard doesn't explain the formula any further, but I will have a go with my bike to verify what values to use and make it all more understandable (or give up).

EN 60034-1 Explains better how to rate an electric motor, the standard isn't free so I can't quote it, but it basically says that a 250w motor must be able to provide 250w all day long without any cool down periods (referred to as duty cycle).

EDIT2: Just noticed that the Annex specifies that the total mass should be equal to 150kg (bike plus rider)
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Re: European regulations

Post by lollandster » Aug 11 2013 12:46pm

I think I have decipherer the formula now:
P=m*(2D^2/T^3)
P = power (watts)
m = mass of bike and rider combined (kg)
D = speed when hitting the 20 meter mark (km/h)
T = Time between starting off and hitting the 20 meter mark (seconds)

I tried the formula with my bike Q100@14amps (manufacture rated) and I got
m = 90kg (rough estimate)
D = 15km/h measured with GPS (not very accurate when speed is not maintained)
T = 5,9s (best of my abilities when riding and operating phone at the same time)
P = 90*(2 * 15^2 / 5.9^3)
P = 197 watts
The 20 meter mark was paced off so not very accurate, this test was only to verify the formula and 197 watts is close enough to the 250 watts rated that I think I've done it correctly.

If anyone thinks I've got this wrong please let me know. It's not easy to know what the author of the standard means when there is no explanation following the formula.

EDIT:
NOTE Considering that on a test track, the engine temperature is not stable, and the grip of the tyre on the road can
be variable, the result of the measurement should be decreased by 1,10 to consider the measurement uncertainty. The
measure is compared to the limit given in the scope of this European Standard.
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Re: European regulations

Post by friendly1uk » Aug 11 2013 1:20pm

Where can this EN15194 be read? I can't seem to find it.
bmsbattery sent me broken and incorrect stuff, and won't even talk to me about it.

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Re: European regulations

Post by lollandster » Aug 11 2013 1:28pm

friendly1uk wrote:Where can this EN15194 be read? I can't seem to find it.
I found it here: http://www.vae-enov.com/fiches_2010/norme_en_15194.pdf
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Re: European regulations

Post by Arbol » Aug 11 2013 2:13pm

Thanks, great explanation.

I still continue without knowing if it is legal to run a say 750W motor limited electronically to 250W via Cycle Analyst, though.

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Re: European regulations

Post by teklektik » Aug 11 2013 5:58pm

Arbol wrote:It seems (I am not a lawyer though) that the only condition is the 250w, 25km/h and PAS conditions must be satisfied. It is not specified how. If one has a 10kW motor, and with a Cycle Analyst power is limited to 250W, it seems it is fine.
Arbol wrote:I still continue without knowing if it is legal to run a say 750W motor limited electronically to 250W via Cycle Analyst, though.
It appears to me that the specification is pretty clear that the limits apply to the bike as a whole. The test procedures address the entire bike in assembled form not components thereof. Using the CA can cause the bike to meet the compliance criteria and a bike so equipped can be demonstrated to adhere to those limits.

The test procedure describes how compliance can be verified, but there is no requirement that you actually do that a priori and the CA will certainly cause the bike to pass the tests should officials deem testing is necessary. For instance, a CA-limited motor will reach and maintain thermal equilibrium at WOT, etc but that will of course be a very low temperature for a 10kW motor limping along at 250W. The absence of specific numeric criteria or of component testing procedures precludes evaluation of the actual maximum power that the motor might develop under conditions other than those as it is installed in the bike.

You seem to have three critical specifications:
  1. Throttle power up to 6kph without pedaling
  2. Assisted power limit of 250W (pedaling required)
  3. no assist over 25kph
All are V3 supported.

The only difficulty that I foresee is the question of whether the CA was engaged in limiting mode. This is the reason that I called out use of a keyswitch above. If you want to try to take this 'CA preset' issue off the table, configure the CA to use an external switch and use a keyswitch that allows the key to be removed in any position. Always pocket the key - never leave it in the bike and mount the switch where it can only be accessed while the the rider is dismounted. After an incident, leave the bike and do not approach it without an officer in tow - point out the keyswitch position before doing anything else. Will this work? Dunno, but you will certainly be making an effort to show compliance which cannot weight against you.

In this country, however, compliance with this sort of regulation is governed by individual states and is in the category of traffic violations - distinctly different than matters that are likely to arise in cases where someone is injured or killed. Then criminal charges (reckless endangerment, vehicular manslaughter, negligent homicide, etc) and civil suits (wrongful death, etc) come into play. In those cases, having an illegal vehicle capable of high speed could conceivably be claimed to be a component of a pattern of recklessness and negligence. These more serious situations are likely addressed in a different fashion in Spain.
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greenspark   100 W

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Re: European regulations

Post by greenspark » Aug 11 2013 6:03pm

Case law is made when the law is unclear and the law is tested in Court. There may already be case law on this, which is why it is worthwhile to pay a lawyer to ask the question. Ultimately however, it will be when a serious event occurs and the State steps in to prosecute. At that point the prosecution (if they care) will press a conservative interpretation to get a conviction, and a defendant will press a liberal interpretation to get a dismissal. If a reputable and large motor maker is involved, and it is a standard motor (not changed in performance from what was shipped), they may choose to defend the case with experts, as it otherwise may threaten their market. The Court will then make case law, but if it is made on your crash, it may prove more costly than you might like.

Thus, the further one deviates from a manufacturer's motor and its specs, the further one moves into risk.

Having said this, the relative risk in the ebike business is probably less than other crimes. In NZ, if you equip your ebike with a motor that exceeds the 300W definition, they then define it as a moped. Reading the requirements for a moped (http://www.nzta.govt.nz/vehicle/classes ... html#moped) you see that except for brakes, all they focus on is lighting and the fact that it must be registered. Lights are easy, especially when one has a large battery. Except for the brakes, there is little focus on safety, such as examining if the frame and fork is up to the stress of the motor, or driving a typical light bicycle on normal badly maintained roads at 49 km/h (such as on a wet cobblestone street, or when hitting a pothole, for example). The brake rules seem to say the brakes must stop the vehicle operating on both front and rear wheels. With modern disc brakes and hub brakes, this is probably easy to achieve, although rubber rim friction brakes (like calliper brakes) may be deemed insufficient for a 49 km/h vehicle. The main pain is that they add NZ$213 a year to register the moped to legally operate on the road and the fine for lapsed rego is $200. I do not know what the EU rules are but expect they would have something similar.

What makes it more interesting is if you use an old bicycle, such as my 1951 Raleigh DL1. Does the addition of the motor mean that it is treated the same as a new vehicle, since certain rules apply only to vehicles made after a particular year. When we motorise an existing bike, what does the law consider we are doing as remanufacture, thus require it meet 2013 standards? Right now, no one is paying attention, and they will not pay attention until there are a number of crashes (I hesitate to call them accidents if the ebike is intentionally overpowered and is therefore intentionally rendered unsafe out of an unfounded sense of ones own immortality). At that point, the bureaucrats in Brussels (or in the several States, be they US, Canada, NZ or Australia) will start writing new and more restrictive rules, probably requiring that kit bikes be inspected and certified with engineers taking life-of-product liability.

For now though, we can enjoy considerable freedom. No certification, no inspections, no registration, no out-of-pocket expenses to governments. If we like this freedom, then it is wise for us to not over-power street-use bicycles, not press the rules and not put ourselves in the position where we become the target of judicial review.

Bottom line, this line of questioning that frequently pops up in this forum, in effect seeks to press the boundaries of ebike law even if the writer is not thinking that way. If someone has successfully pressed the boundary and created precedent, then it is useful for us forum members to know the precedent that we can then follow. However, if we are asking this forum for what are legal interpretations, then we are fools to listen to the answer unless a bike-accident lawyer reads this forum and issues a pro-bono opinion. The alternative is to determine how much risk one is prepared to take on, and that, as always, is no more than a roll of the dice.

My advice? If you want to push the boundaries, do so prudently. Read the rules for mopeds, for example, and equip your ebike accordingly. Put on DOT approved tyres (or at least buy the new Schwalbe range of tyres they say is designed for ebikes). Use stronger rims and thicker gauge spokes. Upgrade your brakes to disk or internal hub (and make sure your front fork is designed to take the different stress). Put on rear view mirrors - in our tests the Mirrycle MTB bar end mirrors are the best we have found (http://www.amazon.com/dp/B0009R96YK/). Avoid a front hub motor unless your fork is designed to handle the torque and you install good torque arms. Install a loud horn, not just a pedestrian-friendly jingle bell. No matter what motor you use (front, crank or rear) examine your front fork to make sure it is up for 49 km/h road impact, and if not, buy another, stronger bike. And yes, put on some turn signals, brake lights and a handlebar-switch-operated head and tail light. Of these, the brake lights may be the most challenging... anyone know who makes an e-brake handle that turns on a brake light?

If you do all of this, you will have demonstrated an attempt to make your ebike safe in the absence of good and clear regulations, thus a court is more likely to accept your defence than if you make a rat-bike designed for pedalling into the most powerful bike you think you can get away with under your own interpretation of the rules.

Or, (if you are in Europe) just buy the Bafang BBS01 250W Eurospec motor and enjoy safe, legal and quite adequate power.

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Re: European regulations

Post by Arbol » Aug 12 2013 12:16am

Thanks for all the thoughtful replies.

Just add two things:

- Yes, it seems the Bafang BBS01 is the way to go: legal, powerful enough, adapted to make the bike an e-bike and not a motorbike ...
- I explicitly do not want to transform an e-bike into a legal motorbike. The main reason is in Barcelona we have many specific bike lines, and especially, some really nice ones, like the picture above going along the beach. You cannot use those if driving a motorbike. The union of beautiness and the lack of risk (driving together with cars and other motorbikes) is what appeals me the most about a bike (apart from doing exercise, of course). I could not do that with a motorbike registered e-bike: I should drive as cars or motorbikes, precluding me to use those bike specific lanes

Probably this is not the right post for this question, but here it is: many people seem very positive on the Bafang BBS01. There are some threads about this motor, but very limited, and with very limited descriptions of real experiences, at least in comparison with other motors. I would like to encourage bikers with this motor to write more about it in this forum, if they have time. Thanks.

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greenspark   100 W

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Re: European regulations

Post by greenspark » Aug 12 2013 12:35am

Arbol wrote:Thanks for all the thoughtful replies.
Probably this is not the right post for this question, but here it is: many people seem very positive on the Bafang BBS01. There are some threads about this motor, but very limited, and with very limited descriptions of real experiences, at least in comparison with other motors. I would like to encourage bikers with this motor to write more about it in this forum, if they have time. Thanks.
As a contributor, I probably have written enough already. But you may find it hard to get many reviews, because it is a new motor, and few are out there. We were one of the first, and in part this is because we were testing other motors of Bafang (like the CST) and they showed us their prototype back in January when we visited the factory. When the motor came out in March, they sent us two of the very first units and we began writing about them as soon as we installed them. You may find some reviews in German as Bafang has focused on the European market. However, Bafang is primarily interested in selling motors in volume to manufacturers. Until one of the Chinese distributors starts offering them, it may be difficult to get single units. We have suggested to Bafang that this is a product where they should consider opening a direct sales outlet, but that seems to be outside the scope of their business plan.

Let me know if you have a source that has them in stock and is selling them. We found one vendor in Germany offering them for about €600 (which seems high), but does not have any in stock.

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Re: European regulations

Post by Arbol » Aug 12 2013 1:21am

Yes, you are one of the very few people reviewing the BBS01, thank you for that.

I will start checking for motor availability in Sep, when back from holidays. I remember I have seen, apart from the German supplier, a couple of Chinese vendors, one selling individual pieces and the other packages of four:

http://www.aliexpress.com/store/product ... 91027.html

http://cnebikes.en.made-in-china.com/pr ... -Bike.html

http://gebattery.en.alibaba.com/product ... _kits.html

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