During the debate on the introduction of Electrically Assisted Pedal Cycles (EAPC’s)into Law the then Under-Secretary of State for the Environment Mr Kenneth Marks voiced his concerns that if the proposer Mr William Whitlock MP was successful then it wouldn’t be long before various people wouldn’t be happy with the EAPC power limits and would exceed them. Experience with the MOPED Class of vehicle had proved it. Mr Marks also stated of the difficulty of altering Transport Law to accommodate changes in legislation. Even so EAPC's passed into Law and this left Government with a quandary. If someone broke the Law concerning the power limits of an EAPC how could they be brought to book. The answer was they couldn’t. Any decent lawyer would point out that their client hadn’t broken any EAPC law as their clients Cycle clearly by definitions was not an EAPC as defined in the Law. It was clearly something else and if the Prosecution could successfully point out what it was and what Law’s relating to it his client had broken, then he would offer a plea of guilty to doing so. And so those who been riding ‘cycles’ with power units that exceed the limits covered in EAPC Law have been virtually immune from prosecution but that is about to change, Governments both here and across Europe have been working diligently over the many years to plug the loop hole and now they have succeeded.
Below are extracts from a letter I received from the DfT (Department for Transport) in response to questions that I asked relating to the illegal use of EAPC’S in the UK.
First things first.
Definitions: Maximum continuous rating:
means the maximum thirty minute of power at the output shaft as set out in UNECE Regulations No 85. Translated, this means the maximum amount of power that a motor can generate without increasing its temperature above the ambient surrounding temperature. Certain classes of motor not for use in EAPC's can under load exceed this rating but get hotter and less efficient in doing so which goes against the dogma of current Environmentalist thinking, consequently, limits on temperature increases have been set so as to limit how long a motor can operate under these conditions before returning to normal operating conditions for a failure to do so would invalidate its type approval conditions as laid down in BS EN 60034-1.
Type Approval.
A means of ensuring that a device is up to the task it is to be used for and that its constituent parts such as motor winding insulating materials are up to task. As far as EAPC motors are concerned they have to have a gradual cut down in power on reaching 25kph or 15mph. There is a control mechanism to prevent ‘overload’ and ‘burn out’ but in what document I have seen it mentioned I have forgotten. If you know where the article is then maybe you could let us know, if not just take my word for it.
Defeat devices:
Any addition of a device whose use would invalidate the result of test procedures used in the issuing of type approval certificates is prohibited. In other words using a device to lower the Maximum Continuous Rating (MCR) of a higher rated device is prohibited.
On Motor ‘peak’ stall point power limits which currently make EAPC motors so versatile.
Government has stated that there is no ‘peak’ power rating as enjoyed at present (560 Watts) other than that of the maximum continuous rating that manufacturers apply to their motors.
If you are struggling to get up hills now you certainly will be when that one comes into force!
On exceeding the power limit.
Quote:
The recent publication of the EU Regulation for Powered Two Wheelers (168/2013) established a new vehicle category for EAPC’S that have a motor output of between 250W* (mistake, should be 251) and 1000 Watts. These vehicles are to be treated as low powered Mopeds and will need Approval, Registration, Licence, Tax and Insurance and the rider must wear a helmet.
End Quote.
As stated above it is not easy to prosecute Law breakers unless all the‘t’s have been crossed and the ‘i’s’ dotted. This has now been done. The finalising and introduction into Law of BS EN 15194 and BS EN 60034-1 with the regard to the category L1e-(A) (EAPC’s) has seen to that.
In order to circumnavigate any ‘entrepreneur’ who has designs on beating the system this eventuality has been covered in the document 168/2013 Article 20(A).
Conclusion:
As Mr Whitlock originally stated, there was a lot of opposition to his proposal to introduce an electric device to power a bicycle. Do Leopards change their spots? When these proposals are introduced in 2016 I believe, my bike, if I can get it go, will have to have its power decreased from its ‘peak’ of 430 Watts by getting a Battery controller plated at 7amps maximum drain which will make it virtually useless for the purpose for which I bought it -climbing serious hills. In any other situation with hills of less than 60 there is no way it can compete with the performance of my ordinary road bike over a test of time.
With the introduction of a ‘moped’ type with all its controls who is going to get one? It will not be me. I don’t think Government is bothered about current ‘E’ class bike riders. I think its target is to get Motor Car drivers to put a ‘folder’ with enough power for the district in the boot and use that to get from out of Town parking or for short trips to the shops. EAPC creators/suppliers will virtually disappear as they could only compete with each other on Cycle looks as the power unit is fixed and who will risk development cost and all that expense with such limited scope for profit margins?
And that’s it.
So now you know. If you are one of those thinking to h*ll with it let me remind you of the words of the Poet/Song writer Mr Bob Dylon ‘the heavily perfumed waters around you have grown and accepting them, soon, you will sink like a stone for the times they are a’changing.
Yours sincerely
Linfitter.
Below are extracts from a letter I received from the DfT (Department for Transport) in response to questions that I asked relating to the illegal use of EAPC’S in the UK.
First things first.
Definitions: Maximum continuous rating:
means the maximum thirty minute of power at the output shaft as set out in UNECE Regulations No 85. Translated, this means the maximum amount of power that a motor can generate without increasing its temperature above the ambient surrounding temperature. Certain classes of motor not for use in EAPC's can under load exceed this rating but get hotter and less efficient in doing so which goes against the dogma of current Environmentalist thinking, consequently, limits on temperature increases have been set so as to limit how long a motor can operate under these conditions before returning to normal operating conditions for a failure to do so would invalidate its type approval conditions as laid down in BS EN 60034-1.
Type Approval.
A means of ensuring that a device is up to the task it is to be used for and that its constituent parts such as motor winding insulating materials are up to task. As far as EAPC motors are concerned they have to have a gradual cut down in power on reaching 25kph or 15mph. There is a control mechanism to prevent ‘overload’ and ‘burn out’ but in what document I have seen it mentioned I have forgotten. If you know where the article is then maybe you could let us know, if not just take my word for it.
Defeat devices:
Any addition of a device whose use would invalidate the result of test procedures used in the issuing of type approval certificates is prohibited. In other words using a device to lower the Maximum Continuous Rating (MCR) of a higher rated device is prohibited.
On Motor ‘peak’ stall point power limits which currently make EAPC motors so versatile.
Government has stated that there is no ‘peak’ power rating as enjoyed at present (560 Watts) other than that of the maximum continuous rating that manufacturers apply to their motors.
If you are struggling to get up hills now you certainly will be when that one comes into force!
On exceeding the power limit.
Quote:
The recent publication of the EU Regulation for Powered Two Wheelers (168/2013) established a new vehicle category for EAPC’S that have a motor output of between 250W* (mistake, should be 251) and 1000 Watts. These vehicles are to be treated as low powered Mopeds and will need Approval, Registration, Licence, Tax and Insurance and the rider must wear a helmet.
End Quote.
As stated above it is not easy to prosecute Law breakers unless all the‘t’s have been crossed and the ‘i’s’ dotted. This has now been done. The finalising and introduction into Law of BS EN 15194 and BS EN 60034-1 with the regard to the category L1e-(A) (EAPC’s) has seen to that.
In order to circumnavigate any ‘entrepreneur’ who has designs on beating the system this eventuality has been covered in the document 168/2013 Article 20(A).
Conclusion:
As Mr Whitlock originally stated, there was a lot of opposition to his proposal to introduce an electric device to power a bicycle. Do Leopards change their spots? When these proposals are introduced in 2016 I believe, my bike, if I can get it go, will have to have its power decreased from its ‘peak’ of 430 Watts by getting a Battery controller plated at 7amps maximum drain which will make it virtually useless for the purpose for which I bought it -climbing serious hills. In any other situation with hills of less than 60 there is no way it can compete with the performance of my ordinary road bike over a test of time.
With the introduction of a ‘moped’ type with all its controls who is going to get one? It will not be me. I don’t think Government is bothered about current ‘E’ class bike riders. I think its target is to get Motor Car drivers to put a ‘folder’ with enough power for the district in the boot and use that to get from out of Town parking or for short trips to the shops. EAPC creators/suppliers will virtually disappear as they could only compete with each other on Cycle looks as the power unit is fixed and who will risk development cost and all that expense with such limited scope for profit margins?
And that’s it.
So now you know. If you are one of those thinking to h*ll with it let me remind you of the words of the Poet/Song writer Mr Bob Dylon ‘the heavily perfumed waters around you have grown and accepting them, soon, you will sink like a stone for the times they are a’changing.
Yours sincerely
Linfitter.