Approved ebike list?

[flecc]

Is there a definition of the period defined as "continuous", obviously from the graph above there are periods ~ albeit very short ~ where the power is continuously above 250w.

I doubt the test periods mentioned in the EN15194 test will be troublesome for the Panasonic system. As the graph shows, the periods at or near 400 watts are very brief and amount to little in total. The occasions of falling to zero are far greater in number and total time. I can't envisage any way a court will accept any part of this is continuous. Japanese law is similar but very much stricter, and the Panasonic 250 watt unit is designed with that in mind.

Graph

 

[Jeremy]

No.
Motor manufacturers used to quote continupus power as a maximum. Their aim was to get it as high as possible because most customers wanted as much as possible. Now for ebikes they want it to be quoted as low as possible, whilst still delivering high power. In theory they can quote "maximum continuous power" as low as they want because they could argue that the motor wears out too fast if you exceed the "maximum continuous power".

If you take a look at either BS1727:1971 (for UK EAPCs) or EN15194 and EN 60034-1 (for EU EPACs) then you'll see that there are very clearly defined definitions for motor power measurement and, in the case of EN15194, an alternative power measurement assessment that is acceptable.

BS1727:1971 takes account of motor temperature rise above ambient when determining "continuous", by noting the point at which the motor temperature no longer continues to increase. As few ebikes are approved using this method it's probably not of much interest, though.

Turning to EN15194 then this uses the motor power measurement method defined in EN60034-1 under these conditions and is similar to BS1727:1971 in many respects:

"4.2.7 Maximum power measurement
4.2.7.1 Measurement at the engine shaft

The maximum continuous rated power shall be measured according to EN 60034-1 when the motor reaches its thermal equilibrium as specified by the manufacturer.
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.

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."

 

[Jeremy]

I doubt the test periods mentioned in the EN15194 test will be troublesome for the Panasonic system. As the graph shows, the periods at or near 400 watts are very brief and amount to little in total. The occasions of falling to zero are far greater in number and total time. I can't envisage any way a court will accept any part of this is continuous. Japanese law is similar but very much stricter, and the Panasonic 250 watt unit is designed with that in mind.

Graph

As the test is based on the motor reaching thermal equilibrium (see my last post) then in effect all those peaks and troughs will be averaged to a fairly low value, I suspect.

 

[Kudoscycles]

But that is the point are they?. Where does it say a 250w bike with a throttle is allowed in law ?

Just because its a accepted pratice amongst UK suppliers does not make it legal

Because,the bikes were tested with throttles and passed EN15194.
This thread is going round in circles and whilst in danger of getting pilloried for it I will try to put some honesty into the conversation.
I tell you that even the DfT do not understand the law,I have a letter at work that has so many ambiguities from the DfT that its really not worth reading. The law is stuck between the 1982 EPAC law and the EU 2003 directive-in the event of a test case and lets hope EN15194 is signed up to before a case becomes reality I think the courts would have difficulty in sorting legality.
Lets be brutally blunt we are putting throttles on our bikes because at least 40% of the customers would not buy that bike without a throttle and on this forum the percentage may be even higher,some customers cannot use the bike without a throttle-my inbox has,at this moment,an enquiry from a Kudos customer who wants to know if he can retrospectively fit a throttle to a Kudos King bike.
With regard to the legality the throttle could be considered a means of changing the PAS power setting and everybody would agree that a PAS control (that is fitted to every ebike) is an essential control for safe passage within pedestrians,the throttle is effectively a fully proportional PAS control-now that statement will probably open up a can of worms but that is the premise that all of us are working to and the EN15194 testers seem to agree.
By the way,boost buttons,are specifically banned under the regulations because they,in some cases,changed the amp setting of the controller and therefore voided the EN15194 regs.
Whilst there are many arguments about the motor power even on 250 watt bikes being outside EN15194 we have to be practical about this-my bikes all seem to exhibit similar performance characteristics,the choice being one of style and specification rather than power-but I have ridden bikes at shows with supposedly only 250 watts that I can pull a wheelie on a bike weighing 37kgs,I have also ridden test S class bikes with 350 watts and bikes in China with 500 watts,these are so much more powerful that the difference is immediately obvious-it is these bikes we want off the cycletracks before someone gets hurt.
As far as my customers are concerned all Kudos bikes meet EN15194,the certificates are there for anyone to view(I take a book of them to every show)and in the event of an accident,assuming the bike has not been DIY modified I think customers should take confidence in that standard.
If ultimately throttles are outlawed for definite,as has recently been the case in Germany then one wire removed from the controller disconnects the throttle.
Now the armchair lawyers can pick the bones out of that lot,but in the current confused situation I think that Kudos and other responsible importers are presenting bikes that people want to buy and with EN15194 certification.
Dave
Kudoscycles

 

[amigafan2003]

Lets just concentrate on enjoying our cycling.

Amen.

Life's too short to worry about miniscule probablity "what if's" - else I'd never get out of bed for fear of the many imaginative ways we can kill ourselves or be killed by others!

Another one of my many varied work roles is as a risk assessor. People unfamiliar with risk assessment think it tries to eliminate all risk associated with an activity. This is false. Correct aplpication of risk assesment ensures that the level of risk is compatible with the associated activity. Just because something "might" happen does not mean the activity should be avoided.

In this respect, I don't think most ebike riders (big or small, 250watts or 1000watts, 10mph or 25mph, throttle or no throttle) have any cause to be unduly worried about thier chosen form of transport if they take reasonable care whilst using thier machines.

 

[Scimitar]

No need for the thick skin Dave, I have been dealing with scum for years.

Typical of you.
Keep going, please. You're just making me laugh my socks off, envisioning you frothing at the mouth as you type off your latest 'witty' retort.
If you had a pen you'd be writing in green ink.

 

[Kudoscycles]

There seems to be a mix of some vendors wanting to be "optimistic" as to what is actually legal, some being simply confused by the whole thing, and some who don't seem to care about legality at all.

Given the difficulty in getting hold of all the required legislative documents and standards, and then the amount of time it takes to read through them carefully and understand the implications, this probably isn't too surprising.

In my view the major failing has been the governments failure to tidy up the law, they should have done it years ago, long before we got to the present situation where we now have a seemingly rapid growth in ebike sales.

If the law is suddenly rigidly enforced now, then there will be a large number of vendors and ebike owners facing serious problems. There is a parallel here with the situation when the government suddenly clamped down on microlight aircraft use in the early 80s. That put several companies out of business overnight and caused hundreds of people to have to scrap relatively expensive aircraft.

The situation is even more identical to the kit car industry,some 15 years ago. At that time you could put 500 hp into a pram frame with bad brakes and as long as it got though MOT (sometimes dubiously!) you could drive it on the road.
The inevitable big accident,insurance companies got the jitters and SVA,since IVA,was introduced. All the small 'death trap' companies dissappeared and the whole industry was tightened up. It caused big problems in the short term but is now a reduced but better engineered industry.
I hope that our government gets off its ..... and signs up to EN15194,with or without throttles,then the future is clear and we can all sell on a level playing field.
Dave
Kudoscycles

 

[tillson]

Typical of you.
Keep going, please. You're just making me laugh my socks off, envisioning you frothing at the mouth as you type off your latest 'witty' retort.
If you had a pen you'd be writing in green ink.

I feel like I am the iceberg to your Titanic. Slowly you drift toward me, inevitable is your humiliating destruction.

I just penned that one Dave, whilst sat outside a very nice pub on a beautiful afternoon dog walking session. The froth around my mouth is from a pint of Black Sheep and very nice it is too. Gotta go, hope to catch you later.

 

[tillson]

People unfamiliar with risk assessment think it tries to eliminate all risk associated with an activity. This is false. Correct aplpication of risk assesment ensures that the level of risk is compatible with the associated activity. Just because something "might" happen does not mean the activity should be avoided.

You are preaching to the converted on this one. I used to have no time for risk assessment until I found a way to make it work for me. Now I'm waiting for delivery of this beauty:



Just need some snow now.

 

[Jeremy]

The situation is even more identical to the kit car industry,some 15 years ago. At that time you could put 500 hp into a pram frame with bad brakes and as long as it got though MOT (sometimes dubiously!) you could drive it on the road.
The inevitable big accident,insurance companies got the jitters and SVA,since IVA,was introduced. All the small 'death trap' companies dissappeared and the whole industry was tightened up. It caused big problems in the short term but is now a reduced but better engineered industry.
I hope that our government gets off its ..... and signs up to EN15194,with or without throttles,then the future is clear and we can all sell on a level playing field.
Dave
Kudoscycles

I tend to agree about the parallel with kit cars, but it wasn't the accident rate that caused SVA to be introduced, it was EU wide vehicle type approval that threatened to ban all kit cars. FWIW I built my last kit car in 1995, shortly before SVA was introduced, so I was pretty much aware of what was going in the kit car world at that time.

SVA was actually a pretty reasonable way around the problem, given the pressure being imposed by the EU, one that many of our EU partners (some of whom still cannot build kit cars) have envied. It at least allowed some kit cars to survive, although for many of the smaller companies, with limited resources, the extra cost involved in ensuring that their kits could be made compliant was just too much and they walked away from the business.

Personally I would love it if there was an equivalent to SVA for ebikes. If we had a simple set of tests, that could be undertaken for a modest fee, and on successful completion we received a certificate to prove compliance then it would remove most of the current crop of problems. The testing isn't hard and can all be done on a short track. It doesn't require anything more complex in the way of equipment than a good stop watch, a set of scales and perhaps some simple electrical monitoring equipment.

Those who are concerned that they may have an illegal ebike, or those that wish to build one from a kit or components, could get it tested and have the comfort of knowing they were legal. Those who aren't bothered could carry on as they do now.

 

[amigafan2003]

Personally I would love it if there was an equivalent to SVA for ebikes. If we had a simple set of tests, that could be undertaken for a modest fee, and on successful completion we received a certificate to prove compliance then it would remove most of the current crop of problems.

That's such a good and logical idea!

Which means no one in government will ever think of it!

I'd be happy to go through that kind of process to have my bike confirmed legal (I'd just have it tested with a 36v battery rather than a 63v battery). The SVA for my kit car was no problem at all - quite enjoyed the experience actually.

 

[Kudoscycles]

I tend to agree about the parallel with kit cars, but it wasn't the accident rate that caused SVA to be introduced, it was EU wide vehicle type approval that threatened to ban all kit cars. FWIW I built my last kit car in 1995, shortly before SVA was introduced, so I was pretty much aware of what was going in the kit car world at that time.

SVA was actually a pretty reasonable way around the problem, given the pressure being imposed by the EU, one that many of our EU partners (some of whom still cannot build kit cars) have envied. It at least allowed some kit cars to survive, although for many of the smaller companies, with limited resources, the extra cost involved in ensuring that their kits could be made compliant was just too much and they walked away from the business.

Personally I would love it if there was an equivalent to SVA for ebikes. If we had a simple set of tests, that could be undertaken for a modest fee, and on successful completion we received a certificate to prove compliance then it would remove most of the current crop of problems. The testing isn't hard and can all be done on a short track. It doesn't require anything more complex in the way of equipment than a good stop watch, a set of scales and perhaps some simple electrical monitoring equipment.

Those who are concerned that they may have an illegal ebike, or those that wish to build one from a kit or components, could get it tested and have the comfort of knowing they were legal. Those who aren't bothered could carry on as they do now.

Unfortunately the kit car certification(now IVA) is anything but simple,kitcar builders prepare weeks ahead for the test and then fail on something simple like a electrical switch not having enough radius on the bezel,the cost is expensive-currently £600 and likely to rise again because the government says that it loses money! and also they are about to close many of the test centres so distance will be a problem-IVA is currently killing the kitcar industry and if they introduce similar for ebikes they will kill that industry also.
If EN15194 is introduced the whole situation will sort itself out,with no need for an IVA equivalent.
Dave
Kudoscycles

 

[amigafan2003]

If EN15194 is introduced the whole situation will sort itself out,with no need for an IVA equivalent.
Dave
Kudoscycles

Well it wont, as there are alot of ebikes out there that are kit or diy converted.

 

[Jeremy]

Well it wont, as there are alot of ebikes out there that are kit or diy converted.

I think that Dave (Kudoscycles) meant by having only EN15194 approval that the whole business will sort itself out for vendors, and killing off DIY builds means more ebike sales..................

 

[shemozzle999]

And for individuals here are the costs:

http://www.dft.gov.uk/vosa/repository/Approvals fees poster 2012.pdf

 

[Blew it]

In my own experiences, Wisper machines fresh out of the box are compliant with EN15194. They are fitted with independant throttles which allow full power without pedalling.. but only to 6 kph. This is useful for standing starts, after which the PAS takes over and the throttle can be dropped.

In many cases, these two wires in the controller housing are disconnected during the PDI which allows independant throttle control without pedalling up to around 17 mph. As a result, the machine is no longer compliant with EN15194, and is illegal under UK regulations due to the 250 watt motor.

All Wisper machines can be returned to full compliance with EN15194 by simply re-connecting the two wires mentioned above. In the event of the UK adopting full compliance with the EU directive, it would be advisable to remove the connectors and solder the wires together to prevent further tampering.

 

[amigafan2003]

I think that Dave (Kudoscycles) meant by having only EN15194 approval that the whole business will sort itself out for vendors, and killing off DIY builds means more ebike sales..................

I was hoping that WASN'T what he meant!

I wouldn't be on an ebike now if the only choice was a shop bought one. Well, actually that's not true because whether my build was legal or illegal wasn;t a part of my decision process.

 

[Jeremy]

And for individuals here are the costs:

http://www.dft.gov.uk/vosa/repository/Approvals fees poster 2012.pdf

Bearing in mind that demonstrating compliance with the core requirements of EN15194, i.e. power assessment, pedelec function assessment, speed assessment, physical inspection of wiring and check on charger compliance with the LV and EMC Directives (by reading the label) is massively simpler than the IVA test.

The ebike in question wouldn't be EN 15194 certificated, as that does require standards of testing applicable for a production, rather than one-off, item, but could nevertheless be issued with a certificate, like the one you get from IVA, stating that the ebike is legal to use in the UK. IVA can only be used for one-offs, so if something similar was introduced then the manufacturers wouldn't be able to use it to circumvent Type Approval.

The test requirements are such that they could be undertaken by a wide range of organisations. If the compliance demonstration model used in small boating is considered, then a voluntary body could oversee the process (as the RYA does with small boat approvals under the Recreational Craft Directive).

 

[Jeremy]

In my own experiences, Wisper machines fresh out of the box are compliant with EN15194. They are fitted with independant throttles which allow full power without pedalling.. but only to 6 kph. This is useful for standing starts, after which the PAS takes over and the throttle can be dropped.

In many cases, these two wires in the controller housing are disconnected during the PDI which allows independant throttle control without pedalling up to around 17 mph. As a result, the machine is no longer compliant with EN15194, and is illegal under UK regulations due to the 250 watt motor.

All Wisper machines can be returned to full compliance with EN15194 by simply re-connecting the two wires mentioned above. In the event of the UK adopting full compliance with the EU directive, it would be advisable to remove the connectors and solder the wires together to prevent further tampering.

Thanks, that clarifies things a great deal. It seems as if there is a sort of pragmatic work around being adopted, in the best British tradition!

As long as owners are aware of the legal situation then this seems fine to me.

 

[shemozzle999]

In my own experiences, Wisper machines fresh out of the box are compliant with EN15194. They are fitted with independant throttles which allow full power without pedalling.. but only to 6 kph. This is useful for standing starts, after which the PAS takes over and the throttle can be dropped.

In many cases, these two wires in the controller housing are disconnected during the PDI which allows independant throttle control without pedalling up to around 17 mph. As a result, the machine is no longer compliant with EN15194, and is illegal under UK regulations due to the 250 watt motor.

All Wisper machines can be returned to full compliance with EN15194 by simply re-connecting the two wires mentioned above. In the event of the UK adopting full compliance with the EU directive, it would be advisable to remove the connectors and solder the wires together to prevent further tampering.

Thanks for the information Blew it, I will check it out.