TONIGHT 9pm: - E-Bikes: The Battle for Our Streets - Panorama

[flecc]

All extant EU regulations were incorporated into UK law with the European Union (Withdrawal) Act 2018 (first proposed as the Great Repeal Bill). As Parliament is sovereign the UK is able to replace any or all of what were originally EU regulations with UK rules. I don't know why you would say otherwise.

I didn't say otherwise, quote:

"The only action open to us now is to cancel the inclusion of this EU law in the Great Repeal Bill, replacing it with our version in British law."

In any case why would the EU care if the UK introduced new standards for power assisted bicycles? The UK is free to change UK laws on pesticides or motor vehicles so what is special about pedelecs?

We are not free to change motor vehicle laws since such EU trade agreements specifically require adherence to EU transport law among others, including assisted bicycles. It was my showing some associated proof of that which started the whole Brexit thread.

BTW The EU–UK Trade and Cooperation Agreement has been fully in force since mid-2021. It is not a temporary agreement.

Apologies. My error due to it being provisional from January 1st 2021, becoming permanent May 1st.
.

 

[flecc]

No it was not. You are jumping in out of the blue and disagree with something nobody has said. Again if you want to say something, say it. Don't get me involved.

Stop being bloody minded. Your implication was blindingly clear, that other courts could be used.

My reply that they could not was entirely relevant.
.

 

[Az.]

Stop being bloody minded.

I find it not only completely irrelevant, but also rude. Over and out.

 

[Peter.Bridge]

Not relevant Peter, being for the following motor vehicles:

• Category M: Vehicles that are primarily used to carry passengers and their luggage.
• Category N: Vehicles that are primarily used to carry goods.

EAPCs are not motor vehicles and anyway, the prescribed motor tests are impossible to carry out without rider input.
.

So this was from REGULATION (EU) No 168/2013 (attached)

Article 2, section 2

2. This Regulation does not apply to the following vehicles:
...
h) pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling and is otherwise progressively reduced and finally cut off before the vehicle speed reaches 25 km/h;

It then defines maximum continuous rated power (on page 7) :

(35) ‘maximum continuous rated power’ means the maximum thirty minutes power at the output shaft of an electric engine as set out in UNECE regulation No 85;

 

[flecc]

I find it not only completely irrelevant, but also rude.

Why, please explain?

You asked me not to implicate you, but surely you implicated yourself when you quoted my post with a clear contradiction.

It was entirely reasonable for me to show that the contradiction could not apply. We all have the right to reply.
.

 

[flecc]

So this was from REGULATION (EU) No 168/2013 (attached)

Article 2, section 2

2. This Regulation does not apply to the following vehicles:
...
h) pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling and is otherwise progressively reduced and finally cut off before the vehicle speed reaches 25 km/h;

It then defines maximum continuous rated power (on page 7) :

(35) ‘maximum continuous rated power’ means the maximum thirty minutes power at the output shaft of an electric engine as set out in UNECE regulation No 85;

Agreed, but as I posted how can one do that with no access to the shaft of the motor in either geared hub motors or mid drive motors when in use. Impracticality which EN15194 also exposed.
.

 

[saneagle]

By that logic why is a 1500W hub illegal, it would run forever at 250W continuous at optimum rpm indefinitely without over-heating?

And no requirement for how much extra power it can handle so sticker granted?

So they don't care about peak current only continuous, even if it can peak at 1800W because
'there is no requirement for how much extra power it can handle?

Eh?

It's illegal because it's rated at 1500w. The max allowed is 250w. We don't need to understand nor question the logic in how the rules came to be what they are. All we have to do is comply with them. Remember, it's their rules, not ours.

 

[saneagle]

What would be interesting to see tested in court (has it ever been? I'm too new to all this to know the history) a motor capable of indefinitely operating at say 500W without overheating, but 'rated' at 250W.

Such a motor passes the measurement test, because the test is designed to assess minimum not maximum continuous power.

Higher courts, if troubled with the issue, would need to rule on the intent of the legislation, which I suspect would come down in a rather more limited way than current practice.

Opponents have a valid point as long as motors well beyond 250W continuous capability are allowed, and it remains trivial via either settings or dongles to bypass the assistance speed limit.

Test what in court? The motor is either rated at more than 250w or not. If doubt about a motor's indicated rating went to court, they'd reference EN60034 pt 1, which is the test standard for motor rating described in EN15194, and ask, "Does it comply?" The answer would be "yes".

Again, it's like you've made your own idea of what should and shouldn't be allowed. EN15194 tells us what's allowed, and in this case it tells us specifically how to test the compliance of the motor rating. EN60034 pt 1 describes in detail the test method and pass criteria for the motor's rating. Why are you trying to make it more complicated than that?

Their rules, not ours, nor the guy down the road's rules, nor anybody else's.

 

[saneagle]

Futility of Motor Power Ratings

"There's no such thing as a rated watt!" Read here for why we don't advertise a simple power rating for the motors we sell. Also, have a look at our Youtube video where Justin talks about the power to propel bicycles in <a href="https://www.youtube.com/watch?v=ALde6zhLPs0">"School of Watts"</a>.

ebikes.ca

Justin completely misses the point in that article. He gives a good explanation about how motors work. He said that people keep asking for the motor's rated power, but he won't give it because it's irrelevant. The reason they ask is for legal compliance, nothing to with how much power the motor can handle. If he does not give a rating, many will not be able to buy it.

 

[saneagle]

So this was from REGULATION (EU) No 168/2013 (attached)

Article 2, section 2

2. This Regulation does not apply to the following vehicles:
...
h) pedal cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of less than or equal to 250 W, where the output of the motor is cut off when the cyclist stops pedalling and is otherwise progressively reduced and finally cut off before the vehicle speed reaches 25 km/h;

It then defines maximum continuous rated power (on page 7) :

(35) ‘maximum continuous rated power’ means the maximum thirty minutes power at the output shaft of an electric engine as set out in UNECE regulation No 85;

That's all irrelevant. EN15194 is the standard for EAPCs, and it specifically calls up EN60034 pt1 as the standard for compliance for the maximum continuous rated power, which details the test method.

 

[Az.]

If he does not give a rating, many will not be able to buy it.

For few extra £ they will engrave rating you want on motor.

Edit:
Found it

Laser Mark 250W on Motor

Laser Engrave 250 Watt Continuous Power Rating on Motor Side Plate. This is Truthfull. ALL Hub Motors Offered by Grin Have an Operating Point (RPM and Allowable Temperature) Where They Can Only Sustain 250W.

ebikes.ca

 

[flecc]

BTW The EU–UK Trade and Cooperation Agreement has been fully in force since mid-2021. It is not a temporary agreement.

I apologised earlier for saying it was temporary, but knew then that it isn't permanent either, since the TCA was clearly a stop gap and admitted as such, to enable trade to continue pending more permanent arrangements. I've now dug out the detail with three quotes:

"Either the UK or the EU can end the UK-EU Trade and Cooperation Agreement with one year's notice. The agreement can also be terminated more quickly if one party breaches certain "essential elements". "

"The UK or the EU can terminate the agreement with nine months' notice, though if the agreement is terminated any obligations will continue until the end of the year. Terminating the fisheries section would automatically terminate the trade, aviation, and road transport sections of the agreement."

Clearly the agreement is NOT permanent if either party can terminate it unilaterally. Even less so with the provisions on "essential elements" and fisheries.

We are seeking specific permanent trade agreements with the EU:

"The UK and the EU signed the Trade and Cooperation Agreement in December 2020, which covers all trade between the two. However, the UK is also working on new trade agreements with the EU to replace those it had as an EU member."

They can be numerous, for example even little Switzerland has 120 such trade agreements with the EU, which took seven years to complete.
.

 

[Woosh]

We are seeking specific permanent trade agreements with the EU:

it's due for review next year.
At the moment, there is no import duty on Chinese BEVs.
I am truly tempted to import one for personal use.
It will be good if we could get the Chinese to set up BEV production here.

 

[flecc]

At the moment, there is no import duty on Chinese BEVs.
I am truly tempted to import one for personal use.

Could have its tricky side, LHD or RHD? And insurance on a grey import might be expensive.

It will be good if we could get the Chinese to set up BEV production here.

Indeed, especially if we could export BYDs etc to the EU.
.

 

[matthewslack]

Basically, at very low speeds, no hub motor will be able to output 250 W because it is operating in an extremely inefficient fashion so would certainly not be able to output 250 w continuously - e.g. a 48V AKM 128 with a 48V 20 amp controller (nominally rated at 800W) going up a 25% hill with 50w of human power can only manage 189 w (and I imagine would overheat very quickly) despite it being rated as 800w by the manufacturer

e.g.

View attachment 61727

Futility of Motor Power Ratings

"There's no such thing as a rated watt!" Read here for why we don't advertise a simple power rating for the motors we sell. Also, have a look at our Youtube video where Justin talks about the power to propel bicycles in <a href="https://www.youtube.com/watch?v=ALde6zhLPs0">"School of Watts"</a>.

ebikes.ca

Hub motors are quite interesting, because of the wide range of operating conditions they have to manage.

Change to the law is highly unlikely, but it would not be difficult or particularly expensive with modern electronics and software to devise a test and a standard that was fit for purpose.

For example, requiring motor and controller to be treated as an indivisible pair for the purposes of testing, and having the controller understand the power/efficiency etc curves so that common sense performance is available both on hills and on the flat.

If the controller understands the power and efficiency curves, it can estimate sufficiently accurately the output power so that hill climbing is not destroyed by enforcing a limit on more easily measurable input power.

Still needs clarity on whether the legislators, regulators and enforcers meant 250W to mean 250W!

 

[matthewslack]

Test what in court? The motor is either rated at more than 250w or not. If doubt about a motor's indicated rating went to court, they'd reference EN60034 pt 1, which is the test standard for motor rating described in EN15194, and ask, "Does it comply?" The answer would be "yes".

Again, it's like you've made your own idea of what should and shouldn't be allowed. EN15194 tells us what's allowed, and in this case it tells us specifically how to test the compliance of the motor rating. EN60034 pt 1 describes in detail the test method and pass criteria for the motor's rating. Why are you trying to make it more complicated than that?

Their rules, not ours, nor the guy down the road's rules, nor anybody else's.

No, I'm not wanting to make rules, and as I said earlier my view, quite strongly influenced by the extensive discussion in this very thread, is that I am not really bothered about actual power output PROVIDED those EAPCs modified or built with peak output power capability way beyond 250W are strictly limited to 25km/h assisted speed.

We cannot expect to have both lax interpretation of what 250W is supposed to mean, and blithely exceed 25km/h without the sort of reactions that non-EAPC riders express.

My interest in the test, and it is a while since I read it in detail, is that it does not establish the maximum continuous power CAPABILITY of a motor, and the flexible approach to RATING any motor at all as 250W according to the test is another guaranteed friction area with anyone who is not the EAPC side of the fence.

Specifically, my logical mind has trouble with rating a motor that would pass the test if tested at say 350 or even 500W at 250W just because it hasn't been tested at higher powers.

That may not be clearly enough explained, but best I can manage after a long day on a roof!

 

[Woosh]

CAPABILITY

The regs don't mention the word capability.
you have electrical sockets and mains conductors rated for 240V yet capable of doing the job at 10 times that, so what's the difference between rating a motor 250W while it's capable of delivering twice that and rating a mains socket at 240V while it can work at 480V?

 

[lenny]

 

[matthewslack]

The regs don't mention the word capability.
you have electrical sockets and mains conductors rated for 240V yet capable of doing the job at 10 times that, so what's the difference between rating a motor 250W while it's capable of delivering twice that and rating a mains socket at 240V while it can work at 480V?

Because the original purpose was to allow EAPCs very limited power in their legal guise as bicycles, and power permitted by rating allows unlimited power!

Nothing to stop a manufacturer rating a 1,000kW motor as 250W in the current arrangements.

 

[Woosh]

Because the original purpose was to allow EAPCs very limited power in their legal guise as bicycles, and power permitted by rating allows unlimited power!

Nothing to stop a manufacturer rating a 1,000kW motor as 250W in the current arrangements.

How will you control such machine?
If your aim is to sell road legal bikes, then why would you want to make illegal bikes or help those who want to break the law?