My bike conforms to EN15194

[Jeremy]

And bike total weight, all three are necessary on the plate, which should be mounted on the bike in a clearly visible position.

I suppose instead of making these modifications you could have added an outrigger wheel to nominally make it a tricycle, and thus 250 watt legal.
.

And if the owner adds a plate to a factory built ebike, then it doesn't mean anything and in fact could be construed as an attempt to deceive. The law clearly states that the plate has to be fitted by the manufacturer. The onus is on the manufacturer to ensure that the data on the plate is accurate.

 

[Old_Dave]

It's 7 AM, the buzzer sounds on the bed side alarm clock...

Itssssssss Groundhog day


Sent from my iPhone using Tapatalk

 

[103Alex1]

I think that it was Lord Denning that said

"in the dictionary for example the word barrister comes directly after bankrupt and just before bastard"

Prize for post of the week goes to ..... Old_Dave

 

[Jeremy]

It is indeed, Groundhog Day......................

I foresee another lengthy debate about motor power, a topic that I thought had been done to death, several times over, in the past few days.

Still, at least it isn't the End Of the World (yet..............).

 

[flecc]

And if the owner adds a plate to a factory built ebike, then it doesn't mean anything and in fact could be construed as an attempt to deceive. The law clearly states that the plate has to be fitted by the manufacturer. The onus is on the manufacturer to ensure that the data on the plate is accurate.

Yes, perfectly true, but I think in a typical circumstance this would not be a problem. For example, a traffic officer investigating an accident and aware of the EAPC requirements might look for the data plate. On finding a professional looking data plate with relevant acceptable details, I think he would just confine himself to such as the dynamic factors of the accident, these having much greater importance in this context.

 

[smudger1956]

I wish I could get a £1 for everytime EN15194 is mentioned...........

 

[Jeremy]

Yes, perfectly true, but I think in a typical circumstance this would not be a problem. For example, a traffic officer investigating an accident and aware of the EAPC requirements might look for the data plate. On finding a professional looking data plate with relevant acceptable details, I think he would just confine himself to such as the dynamic factors of the accident, these having much greater importance in this context.

I'm sure you're right, but there's something about adding a false data plate to an already approved EPAC, in an attempt to deceive anyone looking at it that it complies with laws with which it clearly doesn't, that seems deeply dodgy to me.

Personally, if caught I think I'd fall very much on the side of being totally honest. If I was riding a well-known and competently EU approved ebike then I think I'd very much want to just argue that the problem is that of the government, and not try and deceive anyone, even if the deception might work.

 

[10mph]

To be legal you need to define the motor power output (that is the mechanical output power at the motor shaft) according to the procedure in an old British Standard, BS1727:1971.

This isn't legal, unfortunately, as the law is very clear. If you read the 1983 EAPC regs, then the power that is stated by the manufacturer on the mandatory data plate fixed to the bike has to be determined using the method within BS1727:1971.

If you use any other arbitrary method of defining the "continuous rated output", or of defining the "nominal voltage" other than the method given in the British Standard then the ebike still does not comply with the law.

I dont have a copy of BS1727:1971. I did once see an electric motor power rating spec, probably an EU one, which was based on the manufacturer choosing a maximum temperature for the windings insulation, and then determining the power output when operated at that temperature.

I accept that my testing method may not be the one called for in the specification, but at least I am doing my very best to comply with the regulations as summarised on the Government website, and by the laws of physics it will ensure that the output is less than 200 watts, which I guess is the purpose of the regulations - to ensure that EAPC's do not have more powerful assistance. If I don't derate my Kalkhoff in this way then I will be knowingly running more than 200 watts.

 

[flecc]

I agree Jeremy, my personal approach too, one of acting in good faith which I think will usually be well received by a court.

 

[flecc]

I wish I could get a £1 for everytime EN15194 is mentioned...........

Then you might have £15194.00, or more likely, €18688.00.

 

[10mph]

I'm sure you're right, but there's something about adding a false data plate to an already approved EPAC, in an attempt to deceive anyone looking at it that it complies with laws with which it clearly doesn't, that seems deeply dodgy to me.

Personally, if caught I think I'd fall very much on the side of being totally honest. If I was riding a well-known and competently EU approved ebike then I think I'd very much want to just argue that the problem is that of the government, and not try and deceive anyone, even if the deception might work.

I certainly do not want to deceive, so if I cant test to BS1727:1971 - no plate then.

I had better change the wording on my mode change cover to "200w maximum power" and omit mention of the regs.

 

[RobF]

I wish I could get a £1 for everytime EN15194 is mentioned...........

I'd like a £1 for every word Jeremy has posted on the topic.

 

[Jeremy]

I certainly do not want to deceive, so if I cant test to BS1727:1971 - no plate then.

I had better change the wording on my mode change cover to "200w maximum power" and omit mention of the regs.

Even that might well be stretching things, as the way that the Kalkhoff drive works means that the power varies wildly from one pedal stroke to the next, as the torque sensor power demand changes. One thing we do know is that many (perhaps most) ebikes that are approved to EN15194 (k-ching....£££ !) run at continuous power levels far in excess of the notional 250W. A look here: http://www.pedelecs.co.uk/forum/electric-bicycles/13377-approved-ebike-list-35.html#post162420 may help explain why.

One side effect of this is that reducing power by, say, 20%, may not actually get down to anywhere near 200W "continuous rated power" as required by UK law. I believe that, in the case of the Panasonic drive, changing the power assist level doesn't change the power, as such, either, but rather changes the motor torque assist threshold level. Arguably this is similar to changing the power in some respects, but in practice I suspect that the little motor may well still be kicking out 300 to 400W when trying to climb steep hills. It's hard to be sure, because of the pulsating nature of the drive system measuring electrical input power isn't easy, and measuring mechanical output power at the motor is near-impossible.

 

[10mph]

Even that might well be stretching things, as the way that the Kalkhoff drive works means that the power varies wildly from one pedal stroke to the next, as the torque sensor power demand changes. One thing we do know is that many (perhaps most) ebikes that are approved to EN15194 (k-ching....£££ !) run at continuous power levels far in excess of the notional 250W. A look here: http://www.pedelecs.co.uk/forum/electric-bicycles/13377-approved-ebike-list-35.html#post162420 may help explain why.

One side effect of this is that reducing power by, say, 20%, may not actually get down to anywhere near 200W "continuous rated power" as required by UK law. I believe that, in the case of the Panasonic drive, changing the power assist level doesn't change the power, as such, either, but rather changes the motor torque assist threshold level. Arguably this is similar to changing the power in some respects, but in practice I suspect that the little motor may well still be kicking out 300 to 400W when trying to climb steep hills. It's hard to be sure, because of the pulsating nature of the drive system measuring electrical input power isn't easy, and measuring mechanical output power at the motor is near-impossible.

My Kalkhoff pulses at low cadence and low demand. At medium cadence and high demand the current consumed is steady and reaches a maximum value which is lower on the Mid setting than on the High setting. The Mid setting really does reduce the output power, which is what my objective is.

I understand the point you make in your graph of the EN15194 20m power test. I think the EN15194 is a very poorly constructed spec. You may be interested to see my results from testing in High Assist setting which I posted 18 months ago: http://www.pedelecs.co.uk/forum/electric-bicycles/8743-en19154-power-test-gives-incorrect-high-values.html#post107170

 

[Jeremy]

My Kalkhoff pulses at low cadence and low demand. At medium cadence and high demand the current consumed is steady and reaches a maximum value which is lower on the Mid setting than on the High setting. The Mid setting really does reduce the output power, which is what my objective is.

I understand the point you make in your graph of the EN15194 20m power test. I think the EN15194 is a very poorly constructed spec. You may be interested to see my results from testing in High Assist setting which I posted 18 months ago: http://www.pedelecs.co.uk/forum/electric-bicycles/8743-en19154-power-test-gives-incorrect-high-values.html#post107170

I'd read that post back then, but I should, perhaps, have pointed out at the time that in order to use the Annex D test method the ebike would need to have been modified to remove the need to apply torque to the pedals.

This is allowed, as the regs state that the ebike can be specially prepared for that particular test. All pedelecs would need some form of special preparation for this test method, which is presumably why they allow it.

Manufacturers have, I believe, worked out that the Annex D test assumes constant acceleration rate, and some have adjusted the power application ramp of their controllers to ensure that they don't apply full power initially. This is deliberate, for two main reasons, I believe. Firstly, feeding the power in gently makes for a smoother acceleration with a lot of pedal sensors, and secondly feeding the power in gently allows them to have a much greater continuous power than the regulations would seem to allow, so the ebike will have better hill climbing ability.

Of all the ebikes on the market the Kalkhoff is one of the ones that I'd have least concerns about when it comes to legality, TBH.

 

[RoadieRoger]

Do you think we should go easy on this thread as we might be discouraging potential Ebikers, thereby bankrupting all the Ebike Importers , Suppliers etc . Then we could be giving ammunition to the Legislators who want to tighten the rules or find yet more ways to tax us .This additional tax will be necessary to cover the financial blackhole and finance additional jail space to hold all the Members of this Forum !
Anyway enjoy your Christmas whether you are at home or inside ie jail .

 

[103Alex1]

Lost the will to live several posts back and decided to do what I really love - take my bike certified as EN15194-compliant out for a ride. It proved to be a most rewarding decision and I am still here to tell the tale, thankfully handcuff-free for another day.

In the end, life is too short to wait for regulators and legislators to catch up with their paperwork. If I am had up for riding my bicycle certified as EN15194-compliant after all I have read, I will most likely do what any sane person must do - leave these troubled shores (well, after I am released from prison if needs be) never to return. It will be farewell and good riddance to a country which has totally lost its way and can only be viewed with sadness and pity. My family will be joining me.

Now, my secondary lights have recharged and so I am off to enjoy my life and ride my bicycle. I will do my best to ride responsibly and safely and not to run over any DfT employees on the way. I would far rather they had a great Christmas and did something worthwhile in the New Year to change this sorry state of affairs. One can only hope.

I'm hoping to buy my second eBike in the New Year.

 

[Jeremy]

FWIW I had a great ride on my 600W peak, 25mph capable, ebike this morning. Did I worry about legality? No, because I doubt many people even noticed it was an ebike.

I have three ebikes (plus an electric motorcycle) and frankly haven't ever worried unduly about legality. There are far too many more likely ways to get into trouble than riding a pedal bike with a small electric motor.