I take it the current legislation requires full sva after 2016 for throttles, ie no dispensation yet given? Just trying to work out if we need to start lobbying the DfT.
Will the end of full speed throttles in January 2016 cause a rush to buy.
- Thread starter Kudoscycles
- Start date
A manufactured pedelec fitted with a throttle needs type approval to still be considered an EAPC according to the DfT, but I don't see how that applies to a single kit or home produced pedelec if such is a matter for a national authority.
The statements I'd make and question I'd ask is as follows,
There no single vehicle or type approval class for an EAPC since that law applies to motor vehicles and EAPCs are not motor vehicles.
Therefore, why would the DfT require a home produced pedelec to be single vehicle approved?
Since such single vehicle matters are subject to national and not EU rulings, having a throttle does not require any EU approval measure.
So if the DfT want kit/home produced EAPCs to be single vehicle approved in UK law, they must create a single vehicle class for them with appropriate test fees. The current Low Powered Moped class and forthcoming L1e-A class are completely inappropriate and unsuitable for 250 watt assistance EAPCs, since those classes are for up to 1000 watt mopeds.
Such a single vehicle approval needs only test to bicycle standards since only those apply to the bicycle part, plus a check that the electrical part complies with respect to the laws on maximum power rating, cutoff speed, maximum motor wattage and maximum battery voltage. There is no need to rule on method of power application. Any ban on lever or twistgrip throttle control would be irrational, since a pedelec torque sensor is a throttle anyway, just foot operated, a pedelec sensor is an on/off throttle, and all the power stepping switches on pedelecs are merely multi-stage stepped throttles.
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Heads up:
If going to Spain, wear your helmet (prevents sunburn), keep off the footpaths and leave your throttle at home. I have been warned by friends that there is a prevention campaign on down there at the moment and the police are very zealous... All bikes not just pedelecs.
Yes I am riding down tomorrow
If going to Spain, wear your helmet (prevents sunburn), keep off the footpaths and leave your throttle at home. I have been warned by friends that there is a prevention campaign on down there at the moment and the police are very zealous... All bikes not just pedelecs.
Yes I am riding down tomorrow
C
Cyclezee
Guest
Sorry, haven't actually read any of this
, just wanted to be the one that gave Flecc his 3000th like
Thanks, I hadn't even noticed what my likes had reached. Having looked now I see I'm almost at 30,000 posts, neat linking, 10 to 1.Sorry, haven't actually read any of this
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Just to confirm that there is still no mention of a class of SVA specifically for EAPCs in the recently updated government guide:
https://www.gov.uk/vehicle-approval/motorcycle-single-vehicle-approval
It looks like if you kit build an EAPC that meets the UK requirements i.e. no throttle you are free to use it as an EAPC without any government intervention as no mention of a testing scheme is available but if you want an independent throttle fitted you have to seek SVA moped type approval because of the EU harmonisation requirement but if it is limited to the maximum continuous power of 250W then the government has given dispensation for its use to be identical to that of an EAPC within the UK boundaries.
I know I keep going on about this but...
If you can turn the pedals, without even applying force, you don't need a throttle, modern PAS is really quite good. Yes I mean riding away from the lights on a hill, use your granny gear Luke! The force (all 250 W of it) is with you! Of course you would have to learn how to use it just like I had to relearn how to use my gears now that I have this newfangled 250W motor pushing me along.
If you can't turn the pedals without applying force what the hell are you doing on a bicycle? You should be in a wheelchair...
If you can turn the pedals, without even applying force, you don't need a throttle, modern PAS is really quite good. Yes I mean riding away from the lights on a hill, use your granny gear Luke! The force (all 250 W of it) is with you! Of course you would have to learn how to use it just like I had to relearn how to use my gears now that I have this newfangled 250W motor pushing me along.
If you can't turn the pedals without applying force what the hell are you doing on a bicycle? You should be in a wheelchair...
This is what I question though. The DfT responses to Jonathan imply that SVA is a national matter, so there is no requirement for compliance to the EU pedelec regulations. The requirement to type approve if a throttle is fitted applies only to manufactured pedelecs, since the replies state that type approval only applies to manufactured pedelecs.
SVA isn't type approval since there is no type, each is a one-off.
I think the DfT have got themselves into a tangle of misunderstanding. The following extract from the SVA requirements illustrates just this:
You will be asked to provide certain technical details in relation to the vehicle e.g. maximum speed and power of the vehicle and certain weights. This may be obtained by reference to the manufacturer’s vehicle handbook or from the manufacturer or his agent.
How can one do this when it's a one-off home build being tested, there is no manufacturer? Every time the DfT write on the subject of EAPCs, their confusion shows. I think it comes at least in part from having a motor vehicle mindset, hence the irrational thought that a hand operated throttle makes an EAPC more dangerous than having any other form of variable control. It's clearly motorcycle/car thinking on twistgrips and accelerator pedals.
This should be the correct thinking on this EAPC throttle subject:
Maximum continuous 250 watts is permitted all the time. Any throttle fitted can only reduce that to suit circumstances where less power is required, it cannot increase it. Therefore a throttle is a safety device.
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If you can't turn the pedals without applying force what the hell are you doing on a bicycle? You should be in a wheelchair...
You're an absolute f*cking dick.
I think that Jonathan's advice was obtained from the EU not the DfT.
They side stepped the question of the Commissions definition of an EPAC as a possible infringement of the original treaties and referred responsibility back to the UK authorities. I also noted their disclaimer as to the legality of their advice - so nothing new there then.
If manufactured in quantity it would require only powered cycle type approval and if limited and plated to UK requirement as 250w then it will be classified as an EAPC in the eyes of the DfT.
If self built then from 1/1/2016 it would have to be submitted for SVA the manufacturer being the person who built it. I assume the DfT will further update the SVA classes to accommodate them when the time comes.
They side stepped the question of the Commissions definition of an EPAC as a possible infringement of the original treaties and referred responsibility back to the UK authorities. I also noted their disclaimer as to the legality of their advice - so nothing new there then.
If manufactured in quantity it would require only powered cycle type approval and if limited and plated to UK requirement as 250w then it will be classified as an EAPC in the eyes of the DfT.
If self built then from 1/1/2016 it would have to be submitted for SVA the manufacturer being the person who built it. I assume the DfT will further update the SVA classes to accommodate them when the time comes.
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I really hope so, I'd hate to think them considering the L1e-A class adequate for that.
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Well I am in a wheelchair from time to time. It's not easy to understand disability if you haven't had experience of it but let me assure you there are many out there that can use a bike but can't always use the pedals constantly and consistently.I know I keep going on about this but...
If you can't turn the pedals without applying force what the hell are you doing on a bicycle? You should be in a wheelchair...
WTF!If you can't turn the pedals without applying force what the hell are you doing on a bicycle? You should be in a wheelchair...
Suppose you think Martyn Ashton should stay in his wheelchair?
I think that suppliers of e-bikes go through a moral legality loop,when I first started to build e-bikes I was shocked to see 350 watt x powered 28 mph bikes on the road that were clearly illegal as bicycles,I also saw dongle attached e-bikes that cheated the legal cutoff speed.
The supplier of the Kalkhoff bikes is still trading and blatantly advertising and selling these S class bikes in the UK ,the dealer fitting the dongles to Bosch or Yamaha motored bikes is still trading and openly advertises the effect of fitting a dongle....being blunt about it trading standards doesn't seem to care,the traders don't seem to have any concerns and customers have openly said on this forum that they don't care a hoot about the legality problems of using these bikes.
Let's be honest nobody is going to buy an e-bike just to use it on private land these dongle/S-class bikes are being openly used in exactly the same way as fully legal pedelecs are being used.
The point I am making is that nobody seems interested in whether these bikes are legal or otherwise,least of all the police. What I have read of the new regs seem so ambiguously written that suppliers are confused as to what is required to obtain type approval,even if the mechanism is available to achieve it.
So I am going to supply bikes with throttles disconnected,if customers choose to connect them ( for export use or private land use only sir) then at least the bike will be legal when it leaves my premises,this compares with the dongle/S-class that are not legal when they leave the suppliers premises.
All a bit of a 'storm in a teacup'
KudosDave
The supplier of the Kalkhoff bikes is still trading and blatantly advertising and selling these S class bikes in the UK ,the dealer fitting the dongles to Bosch or Yamaha motored bikes is still trading and openly advertises the effect of fitting a dongle....being blunt about it trading standards doesn't seem to care,the traders don't seem to have any concerns and customers have openly said on this forum that they don't care a hoot about the legality problems of using these bikes.
Let's be honest nobody is going to buy an e-bike just to use it on private land these dongle/S-class bikes are being openly used in exactly the same way as fully legal pedelecs are being used.
The point I am making is that nobody seems interested in whether these bikes are legal or otherwise,least of all the police. What I have read of the new regs seem so ambiguously written that suppliers are confused as to what is required to obtain type approval,even if the mechanism is available to achieve it.
So I am going to supply bikes with throttles disconnected,if customers choose to connect them ( for export use or private land use only sir) then at least the bike will be legal when it leaves my premises,this compares with the dongle/S-class that are not legal when they leave the suppliers premises.
All a bit of a 'storm in a teacup'
KudosDave
I am another with multi-facet disability and agree entirely that there are times when pedalling is difficult. My take on it is this: If I don't quite feel up to pedalling my bike, I don't go out cycling. If I do go cycling but suffer energy loss, total body fatigue and pain, I stop. I stop for as long as necessary to regain sufficient strength to enable me to continue riding, albeit only back home.
Even when we were young, I'm sure most of us stopped riding at times and pushed our bikes or sat down and rested a bit before continuing so I don't see why it need be any different once we become older and weaker.
If my condition worsens appreciably, I may well cease cycling and use a scooter for many of the errands I currently use my bike to perform. Limited walking will then be my only outdoor exercise. Those who ride aboard bicycles yet never pedal aren't really cycling at all so they are not exercising.
Tom
The only thing wrong with what you say is that you are not riding a bicycle you are riding an EAPC.
You chose to purchase one without a throttle which is entirely your prerogative but you then have no choice but to stop and rest.
Others less principled and in my view more sensible have not and have the choice to continue on their journey and recover while using the throttle a far more practical solution to coping with their shortcomings and more likely to promote future electric bike uptake.
You chose to purchase one without a throttle which is entirely your prerogative but you then have no choice but to stop and rest.
Others less principled and in my view more sensible have not and have the choice to continue on their journey and recover while using the throttle a far more practical solution to coping with their shortcomings and more likely to promote future electric bike uptake.
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I live on a continent where a bike is a bike and a moped is a moped. Black - white, no shades of gray.
If you have a throttle you are riding a moped. If you don't have a throttle you are riding a pedelec. Throttles do not promote the sale of pedelecs they promote the sale of a different class of vehicule - which has its place. But is that place on the bicycle path? Here on the continent mopeds belong on the road and pedelecs belong on the cycle path.
Several million people are living just fine here on the continent without a throttle on their pedelec. Of course you have the odd one here and there who has added a highly disguised throttle - often they also have a dongle or other means of getting greater speed or greater power from their moped disguised as a pedelec. People will always break the law. Maybe I am breaking the law by having my max speed set to 27 kph even though that speed is within the tollerance laid down in the law?
Maybe one day soon there will be a crackdown on pedelecs with throttles (there already is one going on in Spain as I write) and on kits because the silly Chinese insist on adding a trottle in every box. That will be bad for pedelec sales and the future of the pedelec because it will take out of the market all those who cannot afford to buy a factory made pedelec.
Executive summary:
Throttles are bad for pedelecs. Throttles are good for mopeds. If you need a throttle buy a moped.
P.S. throttles are the only reason you need brake cuttoff switches on a pedelec too getting rid of both in the kit box would bring the price of kits down.
If you have a throttle you are riding a moped. If you don't have a throttle you are riding a pedelec. Throttles do not promote the sale of pedelecs they promote the sale of a different class of vehicule - which has its place. But is that place on the bicycle path? Here on the continent mopeds belong on the road and pedelecs belong on the cycle path.
Several million people are living just fine here on the continent without a throttle on their pedelec. Of course you have the odd one here and there who has added a highly disguised throttle - often they also have a dongle or other means of getting greater speed or greater power from their moped disguised as a pedelec. People will always break the law. Maybe I am breaking the law by having my max speed set to 27 kph even though that speed is within the tollerance laid down in the law?
Maybe one day soon there will be a crackdown on pedelecs with throttles (there already is one going on in Spain as I write) and on kits because the silly Chinese insist on adding a trottle in every box. That will be bad for pedelec sales and the future of the pedelec because it will take out of the market all those who cannot afford to buy a factory made pedelec.
Executive summary:
Throttles are bad for pedelecs. Throttles are good for mopeds. If you need a throttle buy a moped.
P.S. throttles are the only reason you need brake cuttoff switches on a pedelec too getting rid of both in the kit box would bring the price of kits down.
While I agree with much of what you've posted, I think your attitude to throttles, and also the EU attitude is far too hard line.
When a throttle is added to a legal pedelec, all it can do is reduce the power from the allowed limit, it cannot increase it. So it's a safety measure, not a performance measure. Anyone with experience of both ways knows there are occasions in confined traffic circumstances when the control of an independent throttle improves control and safety beyond that of a pedelec.
The only change adding a throttle makes to the status of the machine is that it becomes an e-bike, rather than a pedelec, it doesn't make it any more unsafe in any way so it remains entirely suitable for access to all cycling facilities.
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