Has anyone sought single vehicle approval and insurance, for a 250-1000w 15.5mph ebike?

[flecc]

Active Link to the above document.
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[Deleted member 4366]

I notice that the standard refers to EPACs but forum members refer to them as EAPCs. I thought I had made a mistake on my labels, but now I remember I made them from the description in the standard.

 

[flecc]

EAPC is the DfT's name for them, derived from the UK's 1983 EAPC regulation name.

Electrically power assisted cycles seems to me to be a less adequately descriptive and more clumsy term than our electrically assisted pedal cycle.
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[shemozzle999]

Active Link to the above document.
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Thanks for correcting the link, original duplicate post removed.

 

[shemozzle999]

Interesting letter to the Commission from former ETRA personnel:

https://circabc.europa.eu/sd/a/55b5d416-aa35-4edb-9a1c-6092af7ff57a/03.c.4 2015_04_13_Letter_Avere.pdf

 

[Deleted member 4366]

EAPC is the DfT's name for them, derived from the UK's 1983 EAPC regulation name.

Electrically power assisted cycles seems to me to be a less adequately descriptive and more clumsy term than our electrically assisted pedal cycle.
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People have to be careful though because the standard is specific. The bike must be marked EPAC. I'm wondering if anybody has messed up by marking their bike EAPC - an easy mistake.

 

[flecc]

Interesting letter to the Commission from former ETRA personnel:

https://circabc.europa.eu/sd/a/55b5d416-aa35-4edb-9a1c-6092af7ff57a/03.c.4 2015_04_13_Letter_Avere.pdf

This letter neatly encapsulates the ongoing storm about independent throttles on e-bikes in any class. The opposing groups never seem able to reach agreement on permitting throttles that act without pedalling.

I find this somewhat strange, since a torque sensor in a pedelec is essentially just a form of throttle.
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[flecc]

People have to be careful though because the standard is specific. The bike must be marked EPAC. I'm wondering if anybody has messed up by marking their bike EAPC - an easy mistake.

That fact that the DfT has merely added a supplement to the existing 1983 EAPC regulation to bring EU conformity instead of replacing with an EPAC regulation makes this mistake very likely for a UK supplier or independent builder.

However, having looked though all the UK statements and regulations on these measures, all only speaking of EAPCs, there wouldn't be any problem from an incorrectly labelled e-bike while in use in the UK. Crossing the Channel would be a different matter of course.
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[Deleted member 4366]

To comply with EN15 15194, the label must say EPAC. The standard doesn't say "EPAC or equivalent"

 

[jonathan75]

Interesting letter to the Commission from former ETRA personnel:

https://circabc.europa.eu/sd/a/55b5d416-aa35-4edb-9a1c-6092af7ff57a/03.c.4 2015_04_13_Letter_Avere.pdf

Oh wow -third or so para from the end is cracking. Exactly what we've been saying.

 

[shemozzle999]

This letter neatly encapsulates the ongoing storm about independent throttles on e-bikes in any class. The opposing groups never seem able to reach agreement on permitting throttles that act without pedalling.

I find this somewhat strange, since a torque sensor in a pedelec is essentially just a form of throttle.
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I fear for the future of the UK market should these regulations take hold.

The governing bodies only appear to be concerned with the inanimate parts and ignore the most important part of the bicycle i.e. the rider.

 

[flecc]

I fear for the future of the UK market should these regulations take hold.

The governing bodies only appear to be concerned with the inanimate parts and ignore the most important part of the bicycle i.e. the rider.

I agree, and the delays while they argue are not helping the market, L1e-A type approval not coming fully into force until 1st January 2017.

Since power level switching does appear to be acceptable, perhaps designers should just get smart to get around the legislation by providing ergonomic multiple level switched control by either twistgrip or throttle style lever. Since Hall effect throttles have a such a poor degree of fine control, as little as five levels could be sufficient to mimic a typical Hall throttle adequately.
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[shemozzle999]

I agree, you mean like the Benelli system:

http://www.benelliebikes.co.uk/technology/

although the electricbikereview reports some snagging in the system:

http://electricbikereview.com/benelli/classica/

 

[craiggor]

Still in the air at the moment I'm afraid, the DfT are not forthcoming with any information yet. L1e-A replaces the low powered moped and L1e-B replaces the 45kph moped class and these are pan EU regulations.

All I've seen is the draft type approval regulation some while ago, but it holds promise. For example:

Lighting was a big bugbear for getting an e-bike approved as a low powered moped since only a proper moped headlight would do, but the L1e-A type approval draft permits this:

White headlight, red rear light, amber cycle reflectors, amber pedal reflectors, red rear reflector, all to be to the standards for normal pedal cycles, ISO 6742-1 and 6742-2.

However, elsewhere I've also found a 500watt hurdle, anything over that requiring a brake light, so that may have to be overcome if it's still in place when the law is finalised.

Another promising item in the type approval draft is that space for a rear number plate is not required for L1e-A. That carries all sorts of implications, with no means of identification would registration, driving licence and insurance be possible? In opposition to that is that a new class Q driving licence has been announced for L1e-A, so the position is very confused and far from clear at present.

And of course the UK can impose additional usage requirements anyway, so I fear we will have to wait until very close to January 2016 which is the next implementation stage before learning the position for L1e-A.

The full type approval legislation for classes L1e-A and L1e-B two and three wheeled motor vehicles won't be completed until 1st January 2017, but most of what we need for L1e-A should be in place at 1st January 2016.

Here's some of the other draft easements and conditions:

No Horn or other audible warning device needed.

If weight under 35 kg:
a) No fluid checking for hydraulic brakes necessary
b) No checking of driver operated controls.
If over 35 kilos, conformity with the braking requirements of UNEC 78 is necessary.

The structural integrity must be that for normal City and Trekking bikes, defined in EN 14764.

Override facilities to increase the restricted speed or maximum power limit which are under the control of the rider are not permitted. N.B. Manufactured L1e-A e-bikes have to conform to specific anti-tampering regulations to prevent overrides. For SVA approval, hub motor and controller systems rated at up to 1000 watts and limiting to 25 kph maximum assist speed are acceptable. Crank motor systems driving through the transmission should have an anti-tampering system that prevents assist speed alteration by altering the gear ratios, e.g. magnetic sensor control of wheel speed etc.
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You say here about no provision for number plate.

 

[flecc]

You say here about no provision for number plate.

That was from the provisional intentions for type approval of L1e-A and L1e-B mopeds. If you read the second paragraph of that post you'll see that I said it was from the Draft Regulation, which of course may change. Since then there have been changes regarding driving licence and insurance which indicate a number plate is very likely to be necessary. We'll know once the law is finalised, maybe as late as 1st January 2017.
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[craiggor]

That was from the provisional intentions for type approval of L1e-A and L1e-B mopeds. If you read the second paragraph of that post you'll see that I said it was from the Draft Regulation, which of course may change. Since then there have been changes regarding driving licence and insurance which indicate a number plate is very likely to be necessary. We'll know once the law is finalised, maybe as late as 1st January 2017.
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So no one can get type approval till then.I can't see how any one can get it for pedelec with throttle as a L1e -A is the lowest in the L class for MSVA.

 

[flecc]

So no one can get type approval till then.I can't see how any one can get it for pedelec with throttle as a L1e -A is the lowest in the L class for MSVA.

I've already told you in a previous post yesterday! This class has always existed, but called Low Powered Moped, so that's what can be used meanwhile. You might not like it's conditions, but that's not the issue, the class is there and has been for many years.

Anyway you don't even need approval for a throttle pedelec now, not until 1st January 2016.
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