Current e-bike wattage.

[ebikeerwidnes]

I am in the middel of filling in the response form

The online version requires too much thought and planning to be done in one session unless you have loads of time

The "download it and email one is badly designed - at least it is if you try to use LibreOffice to fill it in - maybe Word is better??

anyway - I have copied the questions from the web site into a word processor and I am typing up the answers in detail when I get time
I will copy and paste them into the online version when I have done it all

doing it this way as it asks for evidence of things so I have to go off and find actual evidence all the time.


anyway - just saying to give people ideas

 

[bonzobanana]

Well I've done my response. I suspect the majority of people to respond will likely be existing cyclists who may not want to see ebike laws relaxed where as the legislation is likely to improve the situation for many people who aren't currently cyclists and so won't be responding to this.

Q12. Do you support or oppose the proposed change to how EAPCs are classified so that the maximum continuous rated power of the electric motor must not exceed 500 Watts instead of 250 Watts as set out in the current regulations?

Support

Support: reasoning

Q14. Why (including evidence)?

Comment: Existing 250W certified ebikes, for example Bosch and Brose mid-drive motor ebikes are already at 800W or more and classified as 250W. If you look at the certification from the EU it just requires the motor to work at 250W it is not the restriction however UK gov sites state a maximum of 250W so it makes sense to update to new more accurate and rational legislation and certification. Ideally the legislation should be focused on the controller which dictates power not the motor which makes no sense at all because the motor does not control how much power it is given. I would like to see the certification and legislation in line with the USA rather than the ridiculous EU legislation which makes no sense.

Benefits and risks

Q15. If implemented, what do you think are the benefits of increasing e-cycles to 500 Watts?

Support riding up hills and gradients Support use of e-cycles as a mobility aid by disabled people Support use of e-cycles by older people Support use of e-cycles by people who are less physically fit Support use of e-cargo bikes Improved health outcomes Reduced emissions Reduced congestion Another reason: Support for slightly stronger bike frames so those overweight can also use an ebike.

Q16. What, if any, evidence do you have on the benefits of increasing e-cycles to 500 Watts?

Comment: As previously stated most mid-drive motor ebikes that are classed as 250W are already well above 500W, some are at 750W and some beyond that. We already have those ebikes but the legislation is very messy and makes little sense currently. I actually feel like 750W should become the legal limit because then it could encompass existing ebikes like e-mountain bikes with mid-drive motors. If you set the legislation at a real 500W continuous level then what happens to the 800-900W ebikes that are currently legally sold as 250W? Alternatively will the new 500W legislation mean companies can manufacture 1800W mid-drive e-mountain bikes and call them 500W? The EU legislation makes no sense in wattage terms.

Q17. If implemented, what do you think are the risks of increasing the to 500 Watts?

Another reason: Existing ebikes are already well above 250W rating in reality for many models so I don't see the problem. 250W is 7A at 36V or 5A at 48V but certified 250W ebikes have 20-25A at 36V controllers in some cases.

Q18. What, if any, evidence do you have on the risks of increasing e-cycles to 500 Watts?

Comment: There are no risks because 250W ebikes are often 3-4x that power in reality as we have adopted certification standards from Europe which were manipulated to give European manufacturers an advantage. It all depends on how you rate a 500W ebike. If its by the controller itself then you are actually reducing wattage. We need to move to fair and honest legislation just like the wattage of a washing machine or a electric motor-cycle and stop using ebike EU certification.

Throttle assistance

Q26. Do you support or oppose the proposed change to allow EAPCs to have throttle assistance up to 15.5 mph (25 kilometres per hour) without the need for type approval, instead of the existing 3.73 mph (6 kilometres per hour) as currently regulated?

Support

Support: reasoning

Q28. Why (including evidence)?

Comment: There is absolutely no reason to prevent throttle control on ebikes, it is the main power control method for most ebikes in the world across Asia, Africa, South America and North America. It helps so many people who have health conditions and is so easy to understand and use, instinctive. There should never have been legislation against it. Why on earth should the weak, elderly and people with health conditions be denied access to ebikes. Many people are forced to use cadence sensor ebikes which simply operate at full power once the pedals are turning, this is highly dangerous. If anything should have been banned it is cadence sensors linked to full power mode in ebikes. This is not only dangerous in use but discharges the battery at a rapid rate which is more likely to damage cells and lead to battery fires. This again is due to adopting EU legislation which is more about giving EU manufacturers an unfair commercial advantage rather than helping consumers. Expensive EU manufactured ebikes often have torque sensing bottom brackets which is a fine control method ideal for e-mountain bikes but not ideal for urban traffic.

Throttle assistance: benefits and risks

Q29. If implemented, what do you think are the benefits of increasing throttle assistance?

Support riding up hills and gradients Support use of e-cycles as mobility aids by disabled people Support use of e-cycles by older people Support use of e-cycles by people who are less physically fit Support use of e-cargo bikes Reduced cost of e-cycles Improved health outcomes Reduced emissions Reduced congestion Benefits to road safety Another reason: Control of an ebike in urban traffic on congested roads compared to cadence sensors.

Q30. What, if any, evidence do you have on the benefits of increasing throttle assistance?

Comment: It simple enables people to use ebike power as much or as little as they want. This might massively extend the distance achievable on an ebike or in contrast reduce it. It may help improve fitness as you only need to operate the throttle when you are struggling rather than have constant assistance even when you don't need it. Throttles are far more instinctive you don't have to think about them you don't have to think about which power setting to use while you are cycling you simply use more or less power as the situation dictates and brilliant for setting off at junctions more safely especially junctions where you are facing up hill and waiting for a conventional cadence sensor ebike for the power to come in which can be dangerous.

Q31. If implemented, what do you think are the risks of increasing throttle assistance?

Another reason: None of those risks are applicable as we currently have cadence sensors which are more dangerous in those situations. Throttle control would be safer.

Q32. What, if any, evidence do you have on the risks of increasing throttle assistance?

Comment: I can see no evidence from Asia, Africa, North America or South America that throttles are more dangerous. It is the control method used for the majority of ebikes in the world. It is only EU legislation which was done for commercial interests that prevented throttle control not safety implications.

Impact assessment

Q39. What, if any, evidence can you supply on the current size of the e-cycle stock owned by UK transport users and the total annual trips made?

Comment: I don't have that evidence.

Q40. What, if any, evidence can you supply on the current size of the e-cycle market in the UK, including manufacturing volumes, or its potential future growth rate?

Comment: If the UK comes up with its own unique ebike legislation then it will obviously help provide jobs and manufacturing in the UK because we will have unique standards of our own and such companies will be focused on providing products for the UK. I would expect to see more assembly plants in the UK and some growth. Of course European and Asian manufacturers may provide suitable ebikes for the new UK legislation but it won't be their primary focus.

Q41. Do you have any:

estimate of the response that e-cycle manufacturers will have to the proposed regulatory changes and any costs and benefits associated with that response No costs associated with the response that e-cycle manufacturers will have to the proposed regulatory changes No benefits associated with the response that e-cycle manufacturers will have to the proposed regulatory changes No

Q42. What, if any, evidence can you supply on whether and how market prices for e-cycles might be affected?

Comment: If you make ebikes a true maximum 500W then what happens to all the current 250W models that are really 750W or more yet certified under EU legislation? If those ebikes become illegal then obviously their value would plummet.

Q43. Specifically in respect of the proposed regulatory changes what estimate, if any, do you have on the response of:

consumers to any change in e-cycle function and performance – in particular, how it might affect the number of trips taken As it would provide more ebike solutions to people it can only increase. transport users to any change in e-cycle function and performance – in particular, how it might affect the number of trips taken It has to be more.

Q44. What, if any, evidence can you supply on the number and size of businesses that might be affected by these proposals – in particular, whether small and micro businesses may be affected?

Comment: Throttle control is often preferred by people so those importing EU style ebikes might see a reduction in sales. For retailers surely they would adopt to selling products of the new standard. Some independent bike shops are mainly selling highly proprietary high cost ebikes from Europe which cannot be repaired by normal consumers and which have a relatively short life as the frame, motor and battery are all proprietary and expensive to replace or repair. These shops would have invested in expensive equipment to service and repair such expensive bikes. New legislation could effect their business model and reduce sales and servicing of such ebikes which are very complicated to maintain.

Q45. What, if any, evidence can you supply on what impact these proposals might specifically have on disabled people?

Comment: Disabled people of course would massively benefit from these proposals but not just disabled people, people with poor health not classed as disabled but with fatigue issues and other health problems that prevent them starting cycling at all. It would give them an entry point into cycling.

Q46. What, if any, evidence can you supply on what impact these proposals might specifically have on e-cargo bike users?

Comment: I can't see much difference. Already many of those are using high wattage mid-drive motors that are operating at over 800W going up hills. These are certified as 250W despite being over 3x that power. If the legislation is drawn up that these ebikes are limited to 500W only then it would effect e-cargo bikes negatively in that they would have less power. I think legislators need to get in a few engineers to show them the true wattage of legally sold 250W ebikes as it feels like legislators don't realise the reality of the current market.

Final comments

Q47. Any other issues?

While it is stated 15.5mph will be the maximum speed of assistance the UK does not fit in with Europe and I feel an assistance speed of 20mph is the right assistance speed for the UK to fit in with many urban roads that are 20mph and not to cause cars to have to slowdown causing fuel wastage. My own opinion is 20mph should be the maximum assistance speed. I ride my bike at 30mph on flats and sometimes over 40mph down hills. The unassisted speed of ebikes is far more dangerous. Going down a hill is when braking performance is massively reduced and any ebike can go downhill at ridiculous speeds unassisted. I feel 20mph is the safest and most ecologically responsible speed for the UK.

 

[ebikeerwidnes]

Thanks for sharing that - I disagree but you have a valid opinion and it is good to see it put properly

 

[CXRAndy]

I was in support of the changes , but commented that 20mph should be the cut-off limit. To align with the new urban 20mph limit

 

[gbb]

Why should e-bikers feel that they 'need' to be able to ride much faster than me? I struggle to do 5 mph up steep hills and I can ride much faster than 15 mph on the flat!

I reckon that I can only sustain 225-250 W on a good day so an e-biker making any kind of reasonable effort can outpower me as it is. Most seem able to overtake me uphill even on what seem to be currently legal e-bikes.

While there are always a few idiots who get some sort of kick from overtaking ...even though its meaningless because they're on an ebike....do most ebikers even care ? I suspect not in reality, they're riding an ebike, you're riding a 'proper' bike, they're going to overtake you...it's not personal , it's not a point of pride, it's just reality. They probably ride on without a seconds thought about you , me or anyone else.

I was on an ebike ride last year I think and came across a lady on a rozdbike, inevitably caught her up on a hill and settled alongside as we exchanged pleasantries.
She said at one stage....I'm quite envious (of my lack of effort I guessed)
?.
I replied..., no, I'm the one that's envious, I used to ride like you, but can't now....I wished I could, Respect to you.

She smiled, said thanks for the compliment and we went our separate ways.


Like everything in life, it's a diverse mix. There are some morons, there are those that care but most don't really even think about it. Just my thoughts...

 

[Ming the Merciless]

People want safer spaces to cycle, not faster ways to endanger other people.