Let's keep the throttle!

[flecc]

This no doubt influenced the Commissions rejection of the UK appeal for throttles to remain allowed on EAPCs although I have not been able to find any published Commission text on the justification of this decision.

It is a shame that throttle EAPCs and the advantages it would have brought to future disadvantaged riders have been tarred with the brush as the new classes.

Like KTM I'm not aware of any rejection by the EU, it appears the DfT made their own decision about how to proceed.

I agree that it would have been better for throttle permission as an EAPC without type approval to continue in the UK but see this as a lost cause. No matter how many moan about it, the ruling is here to stay and we'll have to live with it.

Some might see hope in the possibility of us leaving the EU, but I doubt that will happen and in any case, the UK's record on e-bike regulation shows us as far stricter than the EU, e.g. 12 mph assist limit, 200 watts and a 14 yrs lower age limit. Clearly the EU is the UK e-bikers friend.
.

 

[Kudoscycles]

I tend to have a practical attitude to these things rather than a legal one.
These e-bikes are fashionable items and the models change too often for small manufacturers to keep type approving every model just to provide a throttle to the small number of customers that want them.
350 watt motors,dongles and 28 mph cutoff speed have always been illegal but I often see these illegal bikes going past our London dealer,in fact some have been bought into for repair. The police and trading standards to my knowledge have not prosecuted anyone using these illegal motorised vehicles,despite trading standards knowing who are the sellers.
Kudos have taken the attitude that our bikes will always be sold legal but the King Display can be adjusted to give greater cutoff than 15.5 mph ,this cannot be modified in error,it's a conscious decision that a customer makes with the knowledge that he makes his bike into a moped.
When I worked for Ford Motor Company there were dozens of spare terminals on a vehicle that were on every car but could only be utilised for export applications. I will take the same attitude to throttles,the bike will be supplied without throttle,but it will be a simple job for a customer to fit a throttle if he chooses.
However,if a particular bike seems to suit a throttle and enough interest is shown and type approval is not too difficult a task then on that bike only we may seek type approval.
The problem of the latter is that you guys have so much variable liking for so many different models that to focus on one bike that is a 'popular one for a throttle model' is unlikely.
Ironically the bigger volumes of mainland Europe manufacturers makes it easier for them to gain type approval,however whether they can be bothered to include throttles for UK only is unlikely.
I am currently specifying 2016 models and will delete full speed (up to 15.5 mph) throttles from all of them but will still offer service items including throttles on 2015 models,which will have similar fitment to the 2016 product.
KudosDave

 

[shemozzle999]

Of course you are happy with the line.

It imposes the EU definition of an EU EPAC over UK EAPC (A for assist) which allows throttles.

Your products are produced to EU standards and this change will reduce your foreign competition in the EU EPAC playing field but I believe it will it will not sit well with UK customers and also reduce the overall market size and interest just as it was expanding.

The comprise to meet the of the opposition arguments for powered cycles being allowed as EPACs, against the definition of an EPAC has nothing to do with safety and usage , is the price we as users have to pay to for the industries expansion into mopeds (S pedelecs)

 

[JohnCade]

Kudocycles.

I’m no expert in this but wasn’t it stated here in a post on the subject of S pedelecs that dealers selling potentially illegal bikes are not committing an offence. But using one is? The point being that until it is used in a public place it isn’t illegal. So the customer is the one who breaks the law.

 

[trex]

I think if a dealer describes his bike as EN15194 compliant but the bike has a full throttle, the customer may later claim that's a wrong description. To make it compliant, the dealer has to reduce the speed on throttle to 6kph.

 

[Kudoscycles]

Kudocycles.

I’m no expert in this but wasn’t it stated here in a post on the subject of S pedelecs that dealers selling potentially illegal bikes are not committing an offence. But using one is? The point being that until it is used in a public place it isn’t illegal. So the customer is the one who breaks the law.

John....we recently built a 500 watt x 23 mph x 48 volt e-bike....it was an experiment to see if it was possible for an average rider weight to ride up a 10% hill without any rider input,using throttle only.
We thought about doing a limited production run,for export or private land use only, but as soon as we built it the practical problems emerged....where would a customer test it,if we let a customer test ride it on the highway we surely would be complicit in providing an illegal bike that at that moment we owned.
I don't know how the sellers of S class bikes or those fitted with dongles get round this,for surely any customer of such a bike would like to test ride it.
With a throttle or king display the problem does not arise because it is easy to offer a test ride on a bike that is sold EN15194 legal,sold with a 4 mph throttle and 15.5 mph cutoff speed.
KudosDave

 

[JamesW]

Lets be simple here - the fact that the UK has/seems to have provision for throttles is great. the fact that the EU doesn't sucks.
I think that people buying e-bikes over here are going to have to be VERY careful as it may be the case that in 5-10 years time we have a goodly number of throttle assisted e-bikes still being sold in this country that will be illegal to ride the second someone straps it on the back of their car and goes through the Chunnel for a holiday. I think the dealers are going to just have to be honest:
"This type of bike you can ride everywhere in europe, and this one is only legal in the UK (and probably parts of the US + China but getting them there is not something that anybody would ever do for going on holiday.)"

 

[flecc]

I must be a bit thick or something, but having read the amendments to the 1983 law, that came into force this year, I can't actually see where it is said that a type approved throttle EAPC/EPAC rider will be treated as an ordinary bicycle rider as far as insurance helmet etc. All I can see is that if it's not a Euro Compliant Pedelec EAPC then it will be treated as a L1E-A which needs License AM etc etc.

Is it buried in some byzantine twist of the documents? Or have I just not read the vital phrase or doc? Otherwise we would only seem to have Clare Perry's word on this...

As you say, the EAPC revision doesn't state anything about throttles, but it's not just Clare Perry's word we need depend on. The IVS (International Vehicle Standards) division of the DfT have made the ruling that an e-bike with a fully acting throttle will be treated as an EAPC if it is type approved and conforms in all other respects to the EAPC regulations.

Looking into that, at present type approval is impractical since the Low Powered Moped method that's in force is too harsh in it's requirements. The new L1e-A type approval that will be available after 31st December 2016 has much reduced requirements, in many things only requiring that the e-bike meets existing bicycle standards. Any good e-bike should pass L1e-A type approval without problems.

Of course the IVS ruling is a UK one which I doubt can apply elsewhere in Europe, but since they specify EAPC, that's not a problem. The EU calls them EPACs in it's laws, so the UK IVS ruling doesn't offend. Clever.
.

 

[Wisper Bikes]

I have been enjoying the good weather of late and made several visits to Willen Lake in Milton Keynes.

There has been a fair on for the school kids and it has been very busy with parents and toddlers.

My throttle and brake cut out switches have come to the fore allowing me to maintain full hand control and safely negotiate around them, something you can't do with a torque sensor as there are no brake cut out switches, the only option being is to switch off the assistance.

Thats a very interesting point, we did make a lot of fuss about slow speed control and the benefits of a throttle. There are now bikes that enable the rider to quickly switch between torque sensor and speed sensor, the best of all worlds.

All the best

David

 

[torrent99]

Ahh so it's not enshrined in law, only in practical application by the uk DfT guidelines? Well that's something (although much easier for a future transport minister or civil servant to change with the stroke of a pen). We shall have to live with that and hope the L1EA requirements are as expected...

 

[shemozzle999]

Like KTM I'm not aware of any rejection by the EU, it appears the DfT made their own decision about how to proceed.

I agree that it would have been better for throttle permission as an EAPC without type approval to continue in the UK but see this as a lost cause. No matter how many moan about it, the ruling is here to stay and we'll have to live with it.

Some might see hope in the possibility of us leaving the EU, but I doubt that will happen and in any case, the UK's record on e-bike regulation shows us as far stricter than the EU, e.g. 12 mph assist limit, 200 watts and a 14 yrs lower age limit. Clearly the EU is the UK e-bikers friend.
.

I got it wrong, it was a few years back it was the European Parliament that made the request but it was attached to the removal of speed limits so I can see why it was rejected, but it was interesting that you say the UK made no such request:

http://www.pedelecs.co.uk/forum/threads/help-with-the-law-please.10740/#post-128887

As it has not been specifically asked before I wonder what the Commissions response to consider only the inclusion of throttles into the EPAC definition and what justification they could give if they were to reject the idea.

 

[shemozzle999]

Thats a very interesting point, we dod make a lot of fuss about slow speed control and the benefits of a throttle. There are now bikes that enable the rider to quickly switch between torque sensor and speed sensor, the best of all worlds.

All the best

David

Hi David,

Interesting compromise but still prefer the independent throttle version although I had to remove its function until I obtained DfT confirmation it was ok to use it.

Really feel sorry for all you dealers even if my posts appear otherwise.

If I were a dealer I would be really annoyed after all the years of effort to build up the UK interest in electric bicycles to see the additional restriction on throttles imposed, without in my opinion, any justifiable grounds on usage or safety.

I am sure there will be ways around it I just hope it doesn't involve the user baring the legal responsibility.

 

[flecc]

As it has not been specifically asked before I wonder what the Commissions response to consider only the inclusion of throttles into the EPAC definition and what justification they could give if they were to reject the idea.

I'm sure their response would be a refusal for several reasons:

The overwhelmingly majority markets in Europe have no problem with the pedelec only ruling.

Adding throttles departs from the principle of the pedelec remaining a bicycle, all motive power being controlled through the pedals.

The well known opposition from the motorcycle interests.

Probably even opposition from the EU pedelec makers, since their investment in development has been solely pedelec for many years. Bosch, Daum, Derby Cycles et al. They might also see permitting throttles as further opening doors to the far Eastern opposition.

These are the reasons for me saying it's a lost cause, I can see no possibility of change to suit us.
.

 

[flecc]

I am sure there will be ways around it I just hope it doesn't involve the user baring the legal responsibility.

There is a way round the law to have a throttle without type approval in the EU. Germany and The Netherlands enjoy it and France will from January 2017.

It's informally called the "S" class.

There is generally a requirement for minimal registration with number plate and insurance, these being set by national governments who also determine whether they can use cyclepaths. No type approval or rider licence is necessary, despite the permitted 45 kph (28mph). And one can have up to a 500 watt rating.
.

 

[shemozzle999]

I'm sure their response would be a refusal for several reasons:

The overwhelmingly majority markets in Europe have no problem with the pedelec only ruling.

Adding throttles departs from the principle of the pedelec remaining a bicycle, all motive power being controlled through the pedals.

The well known opposition from the motorcycle interests.

Probably even opposition from the EU pedelec makers, since their investment in development has been solely pedelec for many years. Bosch, Daum, Derby Cycles et al. They might also see permitting throttles as further opening doors to the far Eastern opposition.

These are the reasons for me saying it's a lost cause, I can see no possibility of change to suit us.
.

No harm in me asking the question to the Commissioner responsible based on usage and safety rather than principle!

 

[oldtom]

Adding throttles departs from the principle of the pedelec remaining a bicycle, all motive power being controlled through the pedals.

The well known opposition from the motorcycle interests.

Probably even opposition from the EU pedelec makers, since their investment in development has been solely pedelec for many years. Bosch, Daum, Derby Cycles et al. They might also see permitting throttles as further opening doors to the far Eastern opposition.

Succinctly put Flecc. The matter of encroachment by a grouping of EAPC makers into lucrative territory currently occupied by moped and scooter manufacturers is a consideration I had never paid much attention to.

Anyone who has spent time in rural France, much of Spain, Italy, Greece and the north African mediterranean countries can't help but have noticed the ubiquitousness of that type of two-wheeled transport. I'd guess that those prolific manufacturers might feel just a little peeved if new legislation were introduced which would impact severely on their sales and livelihood.

I have read and heard the arguments for and against throttles on EAPCs time and time again in recent years but my view hasn't changed. While I can understand their limited usefulness for some in particular circumstances, I cannot accept that they are necessary nor in any way essential for cyclists. Personally, if my legs/heart/lungs give out while cycling, I stop for a breather. I did that 60 years ago on my bikes and I still do it today. If a hill defeats me, I get off and push for a bit. It seems like cheating to me that I should be able to glide along without pedalling and still call it cycling.

If my various conditions deteriorate to the point where I cannot continue riding EAPCs, I shall happily purchase and ride a light motorcycle or scooter for journeys longer than I wish to undertake on a mobility scooter.

Tom

 

[flecc]

If a hill defeats me, I get off and push for a bit.

Indeed, this was commonplace sixty and more years ago when hordes commuted by bike. Long lines could be seen walking up steep hills, pushing their bikes, and anyone trying to struggle up by pedalling would be viewed as odd indeed.

Not surprising of course, considering that bikes were commonly single speed or sometimes three speed hub geared.
.

 

[KTM Bike Industries UK]

The well known opposition from the motorcycle interests.

Probably even opposition from the EU pedelec makers, since their investment in development has been solely pedelec for many years. Bosch, Daum, Derby Cycles et al. They might also see permitting throttles as further opening doors to the far Eastern opposition.

.

also should add, the opposition comes not just from the Motorcycle industry... the majority of the big players in the eBike Industry, it also comes from pretty much the entire cycle industry. Who are working very very hard on access rights for cycles and see ebikes with throttles as mopeds without the legislation - and therefore a big threat to all the good work thats gone on over the past 10 years.

Which is why I think everyone should see the current result as very much a success for the individuals and companies who want to use / sell ebikes with throttles. It was about the best that was always going to happen.

 

[Kudoscycles]

Perhaps after January 2016 a new type will evolve,maybe a vehicle with moped type performance,with a full speed throttle but with the appearance of a bicycle....that would satisfy most requirements.
We have proven that we can get a lot of torque legally out of the BPM hub drive,with the addition of a full speed throttle it may satisfy most requirements.
Just depends how onerous and/or expensive is the type approval.
KudosDave

 

[trex]

then why not go straight for the 'S' type approval?
just change the battery on the BPM bikes for a 48V - cost is same as of now.