Suggestion that delivery companies should check their riders bikes are legal !!!!!!

[Benjahmin]

Agreed, the legislation is very badly framed.
I suspect this is a result of career politicians and civil servants who come out of university with politics, arts or humanities degrees, never have a proper job and claim authority they have no substantia for.
The recent utterances from the covid enquiry have exposed the lack of understanding of scientific methodology amongst the executive. I suspect the same would be true of engineering language and ways and means.
So we get the confusion between 'maximum power' and 'maximum continuous rated power'. Why use 4 words when two will do?

It would be better if the maximum controller power was defined. But, I cant see the muppets in europe or our own self serving ideologues getting a grip on it. Why would they - it won't win votes?

 

[saneagle]

I don't obsess about it at all I simply don't accept a 900W ebike is 250W its as simple as that. You don't buy a 1500W washing machine and expect it to be 5000W and its clear the legislation still views these as 250W ebikes. This corrupt and incompetent legislation has created genuine confusion in the way it is legislated. We now have a huge amount of different motors all with completely different thermal characteristics all claiming to be 250W and to just state there is no maximum wattage rating is just ridiculous, is 50,000 watts acceptable? It's just not how certification is meant to be written, I've read perhaps 100s of certification standards in my time as a Compliance Officer and seen nothing as ridiculous as European ebike legislation in how it is written and implemented.

You only have to look at the government site;

Electric bikes: licensing, tax and insurance

Electric bikes meeting the EAPC regulations can be ridden on the road without being taxed, licensed or insured

www.gov.uk

What counts as an EAPC
An EAPC must have pedals that can be used to propel it.
It must show either:

• the power output
• the manufacturer of the motor

It must also show either:

• the battery’s voltage
• the maximum speed of the bike

Its electric motor:

• must have a maximum power output of 250 watts
• should not be able to propel the bike when it’s travelling more than 15.5mph

There simply isn't a connection between what the certification is allowing and what the legislators are stating, its creating huge confusion.

However I'm not saying ebikes need to be 250W I just want it to be fair to all types of ebikes as so many people on these forums and elsewhere pick and choose what they view as legal based on the farcical certification. We all know 250W was a ridiculous rating that almost no ebike keeps to, the logical continuous output always probably needed to be around 500-1000W for hill climbing and that is pretty much what you get in the USA in their legislation, factual and honest legislation.

It would just seem logical to have ebike legislation suitable for the UK and honest, something like 20mph maximum assistance speed, no restrictions on throttles to be as inclusive as possible and perhaps a continuous maximum wattage rating of 750W to 1000W. It might as well be 1000W to allow existing 250W mid-drive motors to continue to be legal as many wouldn't be legal at 750W. Clear and honest legislation I think would help sell ebikes to the British public as at the moment there is so much talk about illegal and legal ebikes its an un-necessary distraction.

Everything you're saying makes sense. There is only one thing that would make the wording of the standards logical, and that's if whoever wrote and approved it always intended that there should be no upper limit on the motor's output power. We all assumed that they wanted some sort of limit to around 250w average power, but who knows what they actually wanted.

 

[AntonyC]

The weight limit for bicycles was removed which would barely make sense in the context of a hard 250W limit. We should all be hitting the 'Report a problem with this page' button.
EAPC regs, DfT guidelines

 

[flecc]

You only have to look at the government site;

Electric bikes: licensing, tax and insurance

Electric bikes meeting the EAPC regulations can be ridden on the road without being taxed, licensed or insured

www.gov.uk

What counts as an EAPC
An EAPC must have pedals that can be used to propel it.
It must show either:

• the power output
• the manufacturer of the motor

It must also show either:

• the battery’s voltage
• the maximum speed of the bike

Its electric motor:

• must have a maximum power output of 250 watts
• should not be able to propel the bike when it’s travelling more than 15.5mph

There simply isn't a connection between what the certification is allowing and what the legislators are stating, its creating huge confusion.

How do you manage to be so hopelessly wrong? That document is not in any way about certification. What on earth makes you think it is? It is merely a guide, a simple explanation of that is involved if someone is thinking of getting a pedelec.

It is excellent, clearly giving the basic essentials. The reason for mentioning two standards of plating is to reassure that either can be valid since they relate to either side of a change in the law, so can be affected by the age of a machine.

It would just seem logical to have ebike legislation suitable for the UK and honest, something like 20mph maximum assistance speed, no restrictions on throttles to be as inclusive as possible and perhaps a continuous maximum wattage rating of 750W to 1000W. It might as well be 1000W to allow existing 250W mid-drive motors to continue to be legal as many wouldn't be legal at 750W. Clear and honest legislation I think would help sell ebikes to the British public as at the moment there is so much talk about illegal and legal ebikes its an un-necessary distraction.

What you are asking for here is actually impossible, but clearly you do not understand why that is so. Some one else has raised the same issue, so I'll explain later when I have time and link you to the answer.
.

 

[AntonyC]

"a plate showing the instantaneous voltage of the battery"

The acceleration test measures what the bike does (20 m in 6.9 seconds) rather than how it's achieved (250W). Would it have been better for the rules to focus on behaviour generally?

 

[flecc]

Agreed, the legislation is very badly framed.
I suspect this is a result of career politicians and civil servants who come out of university with politics, arts or humanities degrees, never have a proper job and claim authority they have no substantia for.

That isn't even remotely true, the pedelec legislation aspects were and are created over time by a committee of all the interested and most knowledgeable parties. That is necessary in democracies like the UK and EU countries where the sort of dictatorship you suspect would not be acceptable.

Those taking part are all those who could be affected by decisions for the two and three wheeled motorised law and practice, so as well as representatives from the pedelec trade and industry, there are those from the moped and motorcycle interests, safety organisations, police, lawyers etc.

To show there was no lack of knowledge, one of our most knowledgeable members took part in some of the technical meetings, that was scientist Nick, membership name Tiberius, who makes his own pedelecs from the ground up, winning in competition:

Information Link

Another participant has been David Miall, founder of one of our longest established pedelec makers, Wisper.

However, you can see that such meetings have conflicting interests. Any attempts by the pedelec interests to get independent throttles, a higher assist speed, more power, will naturally be opposed by the Moped and Motorcycle interests who see their business will be threatened by pedelecs that do not require a driving licence, insurance, CBT etc., yet perform more like mopeds.

They of course have the powerful safety argument on their side so get the backing of the safety organisations, police etc.

So the law we end up with is unavoidably a compromise, constructed over time to try to satisfy all the interests.
.

 

[flecc]

It would just seem logical to have ebike legislation suitable for the UK and honest, something like 20mph maximum assistance speed, no restrictions on throttles to be as inclusive as possible and perhaps a continuous maximum wattage rating of 750W to 1000W. It might as well be 1000W to allow existing 250W mid-drive motors to continue to be legal as many wouldn't be legal at 750W. Clear and honest legislation I think would help sell ebikes to the British public as at the moment there is so much talk about illegal and legal ebikes its an un-necessary distraction.

I promised you a further answer to this, it is just above to Benjahmin and here it is again on the link below:

Suggestion that delivery companies should check their riders bikes are legal !!!!!!

Agreed, the legislation is very badly framed. I suspect this is a result of career politicians and civil servants who come out of university with politics, arts or humanities degrees, never have a proper job and claim authority they have no substantia for. The recent utterances from the covid...

www.pedelecs.co.uk

.

 

[saneagle]

"a plate showing the instantaneous voltage of the battery"

The acceleration test measures what the bike does (20 m in 6.9 seconds) rather than how it's achieved (250W). Would it have been better for the rules to focus on behaviour generally?

They dropped the acceleration test, presumably because it's absolute nonsense. That must have been put there by a GCE physics student, who'd never ridden an ebike.

As it stands, the standard is pretty good. We don't want or need anything clarified or adjusted because we can get all the power we need. More regulation inevitably leads to less freedom. It would be nice if our government changed the wording in their information to match what's written in the standard.

 

[flecc]

It would be nice if our government changed the wording in their information to match what's written in the standard.

That cannot happen of course since the public information they give out is a con, designed to deliberately conceal the true position on pedelec power. That's to satisfy the moped and motorcycle industry interests and fool others.

For example our MPs. The Committee stage of passing the new regulation through parliament is very revealing of their ignorance of the subject and worth reading through to see what I mean:

http://www.publications.parliament.uk/pa/cm201415/cmgeneral/deleg6/150224/150224s01.htm

.

 

[Bonzo Banana]

How do you manage to be so hopelessly wrong? That document is not in any way about certification. What on earth makes you think it is? It is merely a guide, a simple explanation of that is involved if someone is thinking of getting a pedelec.

It is excellent, clearly giving the basic essentials. The reason for mentioning two standards of plating is to reassure that either can be valid since they relate to either side of a change in the law, so can be affected by the age of a machine.



What you are asking for here is actually impossible, but clearly you do not understand why that is so. Some one else has raised the same issue, so I'll explain later when I have time and link you to the answer.
.

I'm not the only one with this viewpoint from what I've seen written most Chinese manufacturers found the European certification utterly ridiculous and couldn't understand it and many ebike engineers all around the world don't accept the EU certification is certifying true 250W ebikes. It seems now all Chinese manufacturers do is put a 250W rating sticker on their ebikes and restrict speed to 15.5mph assistance to get certified in Europe. It's a complete and utter farce. This confusion for a few years has given the European manufacturers a stronger foothold on their own market but of course has meant the value end of ebikes has been viewed with questionable legality and made ebikes less accessible and maintainable by a huge amount of people.

We are going to need to to change ebike legislation in the future to make it enforceable and fair we can't continue with the train wreck of certification and legislation we currently have. Simple clear certification linked to simple clear legislation that the police can enforce easily. Really all we need is pedals, assistance speed, maybe an acceleration limit and a weight limit. All easily tested with standard police equipment. The wattage is a huge distraction that doesn't really achieve anything in itself. I actually think its a good thing if an ebike can climb a hill at 15.5mph or 20mph and not cause traffic congestion.

 

[flecc]

I'm not the only one with this viewpoint from what I've seen written most Chinese manufacturers found the European certification utterly ridiculous and couldn't understand it and many ebike engineers all around the world don't accept the EU certification is certifying true 250W ebikes. It seems now all Chinese manufacturers do is put a 250W rating sticker on their ebikes and restrict speed to 15.5mph assistance to get certified in Europe.

You just aren't getting it are you? It's a con. All this is intentional, see my answer to Saneagle just above.

And China has exactly the same system, they also adopted the EU's 250 watt law long ago while producing their own e-bikes with 700 watts or more.

We are going to need to to change ebike legislation in the future to make it enforceable and fair we can't continue with the train wreck of certification and legislation we currently have. Simple clear certification linked to simple clear legislation that the can enforce easily. Really all we need is pedals, assistance speed, maybe an acceleration limit and a weight limit. All easily tested with standard police equipment. The wattage is a huge distraction that doesn't really achieve anything in itself.

There you go again, obsessed with certification. No, we won't need to change it and won't be changing it, because nobody is sharing your obsession. Just look at all the countries who have adopted the EU law of a nominal 250 watts while riding with actual powers far above that, including China.

I actually think its a good thing if an ebike can climb a hill at 15.5mph or 20mph and not cause traffic congestion.

My instinct is to agree, but worryingly that means a moped like performance, leading to this:

UK: 50 cc motorcyclist road accident deaths & injuries in Great Britain 2018 | Statista

This statistic illustrates the number of motorcyclists killed or seriously injured in road accidents, with engines of 50 cc or under, in Great Britain as of 2018, categorized by gender and age group.

www.statista.com

.

 

[lenny]

my time as a Compliance Officer

 

[saneagle]

I'm not the only one with this viewpoint from what I've seen written most Chinese manufacturers found the European certification utterly ridiculous and couldn't understand it and many ebike engineers all around the world don't accept the EU certification is certifying true 250W ebikes. It seems now all Chinese manufacturers do is put a 250W rating sticker on their ebikes and restrict speed to 15.5mph assistance to get certified in Europe. It's a complete and utter farce. This confusion for a few years has given the European manufacturers a stronger foothold on their own market but of course has meant the value end of ebikes has been viewed with questionable legality and made ebikes less accessible and maintainable by a huge amount of people.

We are going to need to to change ebike legislation in the future to make it enforceable and fair we can't continue with the train wreck of certification and legislation we currently have. Simple clear certification linked to simple clear legislation that the police can enforce easily. Really all we need is pedals, assistance speed, maybe an acceleration limit and a weight limit. All easily tested with standard police equipment. The wattage is a huge distraction that doesn't really achieve anything in itself. I actually think its a good thing if an ebike can climb a hill at 15.5mph or 20mph and not cause traffic congestion.

You make some good points. The problem is that it's impossible to implement the control measures you suggest because you can't measure the motor's power, when the motor only gives power when you're pedalling. You can only measure the combined power and you've got no way to determine what the pedalling power is. Because of that, you can't have an acceleration test, nor can you do a rolling road/dynamometer test. Those tests would only work if the bikes had independent throttles, but they're not allowed.

The rule is tat you can use any motor rated by the manufacturer at no more than 250W. That's very simple and easy to understand. It's just that most people commenting on it have never read the actual rule, so they invent their own rules based on hearsay and misinterpretation. The rule is very clear. All we have to do is work in accordance with what it says.

One of the main problems is that our government's website has mis-quoted the rule, which is obviously causing a lot of misunderstanding and confusion. That's the only thing that needs to be corrected.

 

[AntonyC]

@BB, look again at the other criteria you gave for What counts as an EAPC. The 15.5mph assistance limit is hard and fast. All the rest (example: "the maximum speed of the bike") explicitly ask for a declaration of nominal value, and each would have a range of 'true' values if taken literally. The correct wording regarding 250W is also clear in requiring only a declaration of nominal value.

It seems now all Chinese manufacturers do is put a 250W rating sticker on their ebikes and restrict speed to 15.5mph assistance to get certified in Europe

That's pretty much all the regs require of any of us. Forget certification compliance, what it does provide is a guideline for a class of vehicles safe enough not to need registration. Perhaps that's as intended.

 

[flecc]

That's pretty much all the regs require of any of us. Forget certification compliance, what it does provide is a guideline for a class of vehicles safe enough not to need registration. Perhaps that's as intended.

Agreed, since the originator of this modern law, the Japanese, had the intention of keeping as close to unpowered bicycles as possible and it was very strict.

The Japanese have determined that the maximum power allowable must not exceed the power the rider puts in (1 to 1), and that this should only be fully available within normal cycling speeds. However, the Japanese have a very different view on cycling speeds to that of UK riders. They regard their common cycling speed as being 15 kph (9.4 mph), and for "sports" riders like our lycra brigade, 24 kph (15 mph), which would raise a laugh from UK club riders who can often average 20 mph for an hour in moderately hilly areas.

Since sports riders don't use electric assist bikes, only the "common" bike's speed is legislated for. Therefore in accordance with that, the design must have integral to it the phase down above full assist at 15 kph (9.4 mph) when the bike is in top gear.

But that's not the end of it, for Japanese law prescribes the power phase down slope as well. Since an analogue slope doesn't readily match digital electronic systems working, Panasonic in an early design for example chose to have four step downs giving a rough tail off of power corresponding with the legal requirement, which is expressed in Japanese law by this equation:

1 - ( [kph - 15] / 9 ) = assist factor

where kph is the road speed.

Quite simply what this means is the road speed in kph, minus 15 (the 1 to 1 kph power assist limit), then divided by 9 produces a result which is subtracted from 1.

In a practical example, at 20 kph (12.5 mph), taking 15 from that 20 kph gives us 5. Then that 5 divided by 9 gives 0.55 recurring. To complete the equation we take that 0.55 from 1 to give 0.45 or 45%, and that's the ratio of rider power that the motor is allowed to assist with at 12.5 mph.

At the lower speed of 11 mph (17.6 kph) using the same calculation, 17.6 minus 15 then divided by 9 and taken away from 1 allows 0.71 or 71% of the riders input given as motor assistance.

At the higher speed of 13 mph (20.8 kph), only 36% of rider input is given by the motor.

The EU followed that model but without the very early progressive power phase down, merely specifying that power phases down as it approaches the 25kph upper assist limit, without saying when that commences. In practice that means almost no phase down, and even the Japanese makers have removed it from export EAPC motors and no longer export complete EAPCs.

The Japanese model shows why asking for precise legislation can have unfortunate consequences. Better the flexibility of the EU law, especially that of the EN15194 "standards" which allows us more practical machines.
.

 

[matthewslack]

Agreed, since the originator of this modern law, the Japanese, had the intention of keeping as close to unpowered bicycles as possible and it was very strict.

The Japanese have determined that the maximum power allowable must not exceed the power the rider puts in (1 to 1), and that this should only be fully available within normal cycling speeds. However, the Japanese have a very different view on cycling speeds to that of UK riders. They regard their common cycling speed as being 15 kph (9.4 mph), and for "sports" riders like our lycra brigade, 24 kph (15 mph), which would raise a laugh from UK club riders who can often average 20 mph for an hour in moderately hilly areas.

Since sports riders don't use electric assist bikes, only the "common" bike's speed is legislated for. Therefore in accordance with that, the design must have integral to it the phase down above full assist at 15 kph (9.4 mph) when the bike is in top gear.

But that's not the end of it, for Japanese law prescribes the power phase down slope as well. Since an analogue slope doesn't readily match digital electronic systems working, Panasonic in an early design for example chose to have four step downs giving a rough tail off of power corresponding with the legal requirement, which is expressed in Japanese law by this equation:

1 - ( [kph - 15] / 9 ) = assist factor

where kph is the road speed.

Quite simply what this means is the road speed in kph, minus 15 (the 1 to 1 kph power assist limit), then divided by 9 produces a result which is subtracted from 1.

In a practical example, at 20 kph (12.5 mph), taking 15 from that 20 kph gives us 5. Then that 5 divided by 9 gives 0.55 recurring. To complete the equation we take that 0.55 from 1 to give 0.45 or 45%, and that's the ratio of rider power that the motor is allowed to assist with at 12.5 mph.

At the lower speed of 11 mph (17.6 kph) using the same calculation, 17.6 minus 15 then divided by 9 and taken away from 1 allows 0.71 or 71% of the riders input given as motor assistance.

At the higher speed of 13 mph (20.8 kph), only 36% of rider input is given by the motor.

The EU followed that model but without the very early progressive power phase down, merely specifying that power phases down as it approaches the 25kph upper assist limit, without saying when that commences. In practice that means almost no phase down, and even the Japanese makers have removed it from export EAPC motors and no longer export complete EAPCs.

The Japanese model shows why asking for precise legislation can have unfortunate consequences. Better the flexibility of the EU law, especially that of the EN15194 "standards" which allows us more practical machines.
.

Impressive level of information, much of which I had not seen before.

 

[Sturmey]

I think there is one big problem with the original suggestion that 'delivery companies should check their riders bikes are legal'. The problem is whether the delivery rider is classified as an 'employee' or a 'contractor'. Normally a company is not responsible for a 'contractors' tools or transport. If the company does check and take responsibility for the delivery riders vehicle, then I think they are blurring the lines between whether the delivery rider is a contractor or an employee and could find themselves in trouble in say the event of a riders road accident in they have already admitted responsibility and therefore liability in checking the riders vehicle.