ETRA eesv, Guinardstraat 32, Gent, Belgium
Phone (32)9-233.60.05, Internet: http://www.etra-eu.com, E-mail etra@pandora.be

Which electric (bi)cycle future do we want?

FRIDAY MAY 13, 2011

Etra is currently lobbying the European Parliament for better technical regulations for electric (bic)cycles and light electric vehicles. Whilst the association was arguing its case on the basis of "encouraging a shift to sustainable mobility" it has found itself unintentionally in a cyclists versus electric cyclists confrontation.

We are wondering where you stand in this debate.

- If you want the market to remain limited to bicycles with pedal assistance up to 25 km/h and a motor output limit of 250W, there is no need to read any further.
-  If you want the market to grow to its full potential allowing different types of electric (bi)cycles and light electric vehicles, i.e. city pedelecs, speed pedelecs, electric tricycles, electric mountain bikes, electric cargo bikes, pedicabs, electric recumbents, velomobiles, … to become widely and easily available, then we invite you to assist ETRA in convincing the European Parliament and Commission that a considerable part of the electric (bi)cycle business is behind the ETRA proposal. Please read on and consider expressing your support for the ETRA proposal.

Today, there are 2 different European regulatory frameworks for electric (bi)cycles and light electric vehicles:

 1.      The Machinery Directive[1] in combination with the EN 15194 standard applies to (bi)cycles with an electric motor that assists up to 25 km/h and has a maximum continuous rated power of 250 W.

2.      The type-approval procedure for motorcycles[2] applies to (bi)cycles with an electric motor that assists above 25 km/h and/or has a maximum continous rated power of more than 250W, as well as to all bicycles that can be propelled by the motor itself.

The differences between the 2 regulatory frameworks are very important:

 1.      Classification under the Machinery Directive + EN 15194 means:      .

a.      that the manufacturer can self-certify. He has no legal obligation to use an accredited lab to test his vehicle;
 b.      that his vehicle as a whole needs to comply with the rules, not the separate components;
c.       that components can be freely replaced, provided the whole vehicle continues to comply with the rules;
d.      that components do not need to be type-approved if used as spare parts;
e.      that the vehicle is classified in such a way that the rider can use it with no further obligations;

2.      Classification under the type-approval for motorcycles means:

a.      that the manufacturer can only obtain certification through an accredited lab;
b.      that not only the vehicle needs to be type-approved but also most of its components;
c.       that components can only be replaced by type-approved components;
d.      that changing a component means going back to type-approval;
e.      coping with type-approval requirements that are designed for motorcycles, thus technically not adapted for electric bicycles and light electric vehicles;
f.        classification of the vehicle as a moped as a result of which riders can only use it with a helmet, drivers’ licence, insurance, number plate, …

End of last year, the European Commission has developed a proposal[3] aimed at updating the type-approval procedure but has omitted to introduce any changes for the benefit of electric bicycles and light electric vehicles. On the contrary, the European Commission proposes even more inapppropriate requirements such as for instance On Board Diagnostics, anti-tampering measures for the powertrain (which includes gears, brakes, …) and wheels that should be able to rotate at different speeds at all times for safe cornering. This proposal is now in the European Parliament that is expected to amend the Commission’s proposal.

 ETRA has been lobbying the European Parliament for 3 main issues:

1.      as for bicycles with a motor that assists up to 25 km/h irrespective of their motor output limit: exclusion from the type-approval for motorcycles and inclusion in the regulatory framework of Machinery Directive + EN 15194

2.      as for bicycles and light electric vehicles with an electric motor that can propel the vehicle itself which do not weigh more than 25 kg and travel no faster than 25 km/h: exlusion from the type-approval for motorcycles and inclusion in the regulatory framework of Machinery Directive

3.      as for all other electric bicycles and light electric vehicles that will be included in the type-approval for motorcycles: requirements that are adapted and appropriate to these vehicles.

In ETRA’s position paper[4] that was submitted to the European Parliament and Commission you will find a detailed explanation, as well as all the amendments that are needed to implement the 3 principles above.

Today, the members of the European Parliament are confused. They are being lobbied by representatives of cyclists and of the bicycle industry who argue that more electric (bi)cycles and light electric vehicles on the road will endanger the safety of “conventional” cyclists. They want to make sure that the market remains limited to (bi)cycles with pedal assistance up to 25 km/h and a motor output limit of 250W.

ETRA believes that its proposal will have no negative effects on road safety. ETRA believes on the contrary that there is a huge potential for developing the market of electric (bi)cycles and light electric vehicles, a potential for convincing people and companies to swap from cars to electric cycles for certain trips. More electric cycles on the road will mean less cars thus improved road safety for all vulnerable road users. However, this potential cannot be unlocked if manufacturers are confronted with a regulatory framework that is not appropriate, which is the case today.

Conclusion:

-  if you want the market to remain limited to bicycles with pedal assistance up to 25 km/h and a motor output limit of 250W, you do not need to do anything
-  if you want the market to grow to its full potential allowing different types of electric (bi)cycles and light electric, i.e. city pedelecs, speed pedelecs, electric tricycles, electric mountain bikes, electric cargo bikes, pedicabs, electric recumbents, velomobiles, … to become widely and easily available, then we invite you to assist ETRA in convincing the European Parliament that a considerable part of the electric (bi)cycle business is behind the ETRA proposal.

You can support ETRA by co-signing the joint letter attached below this article and returning it by E-mail to etra@pandora.be as soon as possible.

The draft report of the European Parliament on the review of the type-approval has been published on 5 May 2011[5]. The Rapporteur, Wim van de Camp, has not yet introduced any provisions for the benefit of electric cycles and light electric vehicles because he is still considering the safety issue. The deadline for such provisions is end of June. It is our intention to send the joint letter to him, to all other MEPs and EU officials in order to convince them of the necessity and the support for the ETRA proposal.

Please contact the ETRA secretariat for any further details you may require.

Available downloads

Jointletter.doc (Microsoft Word-document, 34Kb) Joint letter

Discussion

Is there a petition to sign against this? I think many electric bikers would sign it. Also who are the cycling organisations that are lobbying against improved electric bikes? I am a member of at least one cycling organisation and would like to know.
(By Nick Flynn, May 14, 2011 23:18 | React to Nick Flynn)

ETRA is misrepresenting cycling organisations, when it says they are against the improvement and expansion of electric vehicles. I can only speak for CTC, but I know that we very much encourage the development of light electric/pedal-powered freight vehicles and have no objection to electric mopeds - provided they stick to the roads. What we object to is the fiction that a vehicle propelled by a motor with a continuous rated output exceeding 250W is "electrically assisted". 250W is already substantially more than the continuous rated output of most human pedallers. More electrical power than that and we can no longer pretend to have anything other than a pedal-assisted motor vehicle. The fact that a motor is turned on by rotating pedals rather than twisting a handle is not of itself sufficient to make the vehicle primarily pedal-powered. What we have, with any higher power and/or higher speed pedal/electric vehicle is quite simply and obviously an electric moped. It is a nicer thing than a petrol moped and should therefore be encouraged, but still a moped. Those with a top speed not exceeding 25kmph might well be permitted in areas from which other motor vehicles are excluded. They nevertheless resemble mopeds more closely than they resemble pedal cycles and so we consider that type approval is appropriate. There is probably a case for a new lighter touch category of type approval to cover these vehicles. And their zero emission credentials should be recognised in other regulations, provided there remains a clear distinction between vehicles that are primarily human powered and those that are primarily motorised.
(By Chris Juden, May 18, 2011 12:04 | React to Chris Juden)

Chris you said >What we object to is the fiction that a vehicle propelled by a motor with a continuous rated output exceeding 250W is "electrically assisted". 250W is already substantially more than the continuous rated output of most human pedallers. ......That 250 is input watts to the motor. Most E systems are about 50 % to 60 % efficient. That means the power to the ground is 125 to 150 watts. However combine E power to the Human Power equals a LOT of total power. Yet people seem to still be addicted to wanting more "assisted" power which then I believe makes this into a motorized vehicle. Higher power means the motor and gear box and battery has to be large - meaning heavy. This weight and higher vehicle speeds puts a strain on the bicycle components threfore the bike needs to be upgraded winding up like a moped. John Tetz
(By John Tetz, June 7, 2011 03:14 | React to John Tetz)

John, As Chris said, the limit relates to the continuous output rating of the motor, not the input power or the peak output power. It can be exceeded for a period determined by the thermal inertia of the motor. High mass hub motors can exceed the limit for a considerable time......
(By Miles Hellon, June 7, 2011 09:56 | React to Miles Hellon)

"The anticipated correlation between safety and absolute power limitation could not be confirmed in several scientific studies." These are not ETRA's words but the European Commission's words. On the basis of that conclusion, the European Commission proposes to abandon a 74 kW motor output limit for motorcycles. How can one at the same time defend a 0.25 kW limit for pedal assisted bicycles? The European Transport Safety Council (ETSC) has approved the Commission's proposal to abandon 74 kW. So far, we have not seen any statement of ETSC warning for the safety risks that may arise from our proposal. Also, as we continue to repeat, type-approval is a set of rules that do not determine where vehicles can or cannot ride. That is determined by the traffic code. Type-approval is a set of rules that determine how vehicles should be constructed in order to be safe. So if cycling organisations do not want certain pedal assisted bikes on certain infrastructure, they need lobbying their national transport minister, not the European institutions dealing with the review of the type-approval.
(By Annick Roetynck, May 18, 2011 16:53 | React to Annick Roetynck)

In fact the market of 500W continuously assisted bicycles will grow regardless the current regulations. There are many consumers who are really able to use ebike only with stronger motor and producers are trying to satisfy them. For the electric MTB where the climbing ability is the main advantage the electric motor producers are giving more torque and hard to measure if its still really 250W or much more :)
(By Jakub Ditrich, May 24, 2011 18:14 | React to Jakub Ditrich)

Jakub you wrote; >In fact the market of 500W continuously assisted bicycles will grow regardless the current regulations. There are many consumers who are really able to use ebike only with stronger motor and producers are trying to satisfy them. .............I know what your saying is true but I wish it wasn't true. I wish that in the 21st century where we are finnaly aware of what is happening to the environment we would be trying to do more with less. Trying to break the 19th and 20th century industrial growth habits of assuming there is unlimited power and energy available to us is going to be damn hard.
(By John Tetz, June 7, 2011 03:31 | React to John Tetz)

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