Etra

eddieo

Banned
Jul 7, 2008
5,070
6
what would be useful is an "easy swap kit" so the wisper 500 watt wheel has a plug and easy interchanged with the original 250 watt wheel

then I could change to the more powerful set up easily when visiting Italy/Switzerland or any place where the hill climbing is more difficult. the range could be a problem but with decent power management a range of 30 miles would probably do:)
 

Wisper Bikes

Trade Member
Apr 11, 2007
6,341
2,297
70
Sevenoaks Kent
Briefing for ETRA meeting

Briefing for the meeting on European electric bike regulations Brussels – 29 September 2009

1. Current situation

All EU member states had to implement Directive 2002/24/EC concerning the type-approval of two or three-wheel motor vehicles.

Pedal assisted bicycles with
Motor automatically cuts out at 25 km/h
Motor output up to 250 W
are excluded from Directive 2002/24/EC, therefore are not subject to moped and motorcycle type-approval bicycles, therefore member states have the right to impose specific requirements, as UK has done subject to EN 15194

Pedal assisted bicycles with
Motor assists beyond 25 km/h
Motor output exceeds 250 W
Bicycles that can be propelled by the motor itself are included in the Directive 2002/24/EC, therefore are subject to moped and motorcycle type-approval mopeds, therefore member states have to right to impose specific requirements with reference to helmets, age limits, number plates, insurance, etc

The Commission is currently reviewing Directive 2002/24/EC. This creates an opportunity to start discussions with the Commission on 2 issues:
1) the 250 W and 25 km/h limit for pedal assisted bicycles to be excluded from the type-approval
2) developing a type-approval procedure which is appropriate for electric bicycles

2. Report on the contact with the European Commission and clarification on the framework of the review

The Commission is currently making an impact assessment of the review of the type-approval. This is a crucial stage for obtaining a change in legislation for electric bicycles. The Commission needs to include that change in the impact assessment. For that purpose, they require three things:

1) a categorisation of electric bicycles
2) a list of technical aspects of the bicycles that need to be type-approved to ensure safety
3) the testing procedures for the type-approval of the listed technical aspects.

We still have some time to develop above-mentioned point 2 and 3. However, for point 1, the Commission requires a proposal before the end of this month! Therefore, the meetings in Las Vegas and in Brussels should result in:

1) definition of the criteria for the exclusion of electric bicycles (now 250 W, 25 km/h)
2) categorisation of electric bicycles not excluded from the type approval.

3. Discussion on the specifications for excluding electric bikes from the type-approval


The exact wording of the current exclusion of pedal assisted bicycles from the type-approval is as follows:
“cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of 0.25 kilowatts, of which the output is progressively reduced and finally cut off as the vehicle reaches a speed of 25 km/h, or sooner, if the cyclist stops pedalling.”

I have asked our contact at the Commission what would be a realistic proposition to him, but he answered that he has no idea. In any case, our proposition would have to ensure that the excluded electric bicycles are safe. As a by the by, there is another European Directive which states that only safe products can be put on the market. Furthermore, one has to keep in mind that a change of the specifications for exclusion will entail a change of EN 15194, which has been developed for pedal assisted bicycles up to 250 W and 25 km/h.

Perhaps, the American specifications could be kept in mind. The fact that these guarantee safety in a way that is satisfying American authorities should be a quite convincing element for the European authorities. Furthermore, it would allow us to argue that if the same specifications apply in Europe and in the States, the industry will benefit from the resulting economies of scale

Conclusion: the meeting should result in a proposal for the exclusion of pedal assisted bicycles based on a sound and solid argumentation

4. Discussion on how to develop a type-approval specially designed for not excluded electric bikes

As explained above, this requires three elements:

1) a categorisation of electric bicycles not excluded from the type-approval
2) a list of technical aspects of the bicycles that need to be type-approved to ensure safety
3) the testing procedures for the type-approval of the listed technical aspects

The meeting should result in a proposal for the categorisation of electric bicycles not excluded from the type-approval. We have to submit a proposal to the European Commission before the end of September.

Today, Directive 2002/24 contains definitions of the different categories of mopeds and motorcycles.

The category to which pedal assisted bicycles above 250 W and 25 km/h belong is “Mopeds”, defined as:

Two-wheel vehicles (category L1e) or three-wheel vehicles (category L2e) with a maximum design speed of not more than 45 km/h and characterized by:
(i) in the case of the two-wheel type, an engine whose:
. cylinder capacity does not exceed 50 cm3 in the case of the internal combustion type, or
. maximum continuous rated power is no more than 4 kW in the case of an electric motor;
(ii) in the case of the three-wheel type, an engine whose:
. cylinder capacity does not exceed 50 cm3 if of the spark (positive) ignition type, or
. maximum net power output does not exceed 4 kW in the case of other internal combustion engines, or
. maximum continuous rated power does not exceed 4 kW in the case of an electric motor;

Our contact at the Commission has stated that he is prepared to propose a subdivision of category L1, which could be as follows:

L1 – A: bicycles with an electric motor ….. (to be further defined by the industry)
L1 – B: mopeds with an electric motor … (to be further defined by the industry)
L1 – C: mopeds with an internal combustion engine

With that, the following needs to be kept in mind. The current European type-approval procedure contains specific requirements for 47 components and characteristics to which the conformity of new vehicles must be checked. Electric bikes are exempted of 12 of these requirements, but must conform with the remaining 35 requirements.
For 9 items, the law stipulates that specific requirements will be laid down for low-performance mopeds, i.e. mopeds with pedals, with an auxiliary engine of power not exceeding 1 kW and a maximum design speed not exceeding 25 km/h. So far, the Commission has failed to determine these specific requirements. The requirement list is in an annex to this document.

As said, for now we only require the categorisation. The proposal will be subject to the co-decision procedure, which means that both the European Council (of national ministers) and Parliament will take a final decision on the proposal. That is good because that gives us additional opportunities to lobby for what the industry wants.

However, the industry should take into account that the work does not end here. After our proposal for categorisation, we still need to list the technical elements of the bicycles that will need to be type-approved to ensure safety and specify the testing procedures for the type-approval of the listed technical aspects.
 

flecc

Member
Oct 25, 2006
53,616
30,884
Perhaps, the American specifications could be kept in mind. The fact that these guarantee safety in a way that is satisfying American authorities should be a quite convincing element for the European authorities. Furthermore, it would allow us to argue that if the same specifications apply in Europe and in the States, the industry will benefit from the resulting economies of scale.
Many thanks for this full appraisal of the current position David, much appreciated.

The snag I see in the use of the US example is the way that the State legislatures can overrule the national legislation, meaning they don't in practice have a national standard. Some States have set lower maximum powers etc, and one state has an outright ban of e-bikes! As in the Italian example though, the one saving grace is that these laws are almost universally ignored.
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Straylight

Esteemed Pedelecer
Jan 31, 2009
650
2
Wow, having just looked up the U.S. legislation, I have to say I'm impressed, was expecting something much more conservative. As you say though Flecc, an individual state's ability to overide it relegates it to the power of a guideline, as would an equivalent condition here.

On the subject of campaigning, it was just a thought, as whenever one googles anything e-bike related, this forum pops up high if not top of the list, so it stands to reason that it would be a port of call for any interested party.
 
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flecc

Member
Oct 25, 2006
53,616
30,884
On the subject of campaigning, it was just a thought, as whenever one googles anything e-bike related, this forum pops up high if not top of the list, so it stands to reason that it would be a port of call for any interested party.
I agree that pedelecs is high in Google's search criteria, due in no small part to the work of Russell Scott, our administrator, in working with Google in the early days to achieve good rankings.

I can't help feeling, like many people, that European legislators aren't as interested in what their subjects think as they should be. Like our parliament, they increasingly rely on specialist committees and sources to provide them with information, the public held at a remove with little or no influence. I can understand that basic attitude, if the majority public had the whole say we'd probably be riding 1000 watt 30 mph e-bikes to see public hangings, but the isolation of the population from decision making has gone too far in my opinion.
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Straylight

Esteemed Pedelecer
Jan 31, 2009
650
2
Absolutely, and considering that the person most endangered by a cyclist is the cyclist themselves, I believe that most of us could be trusted to behave responsibly.
 

flecc

Member
Oct 25, 2006
53,616
30,884
Agreed too, and I think the desire for the limit to be 20 mph is pretty well universal amongst e-bike enthusiasts, and probably among those e-bike commuters who might not be enthusiasts. I don't suppose the shopper bike crowd are too bothered since many of the cheap bikes they buy only run to about 13 mph on a good day and Tesco usually isn't too far away.

Perhaps one day the EU might relax their rules, but as our bike class permits member nations to place restrictions in addition, we might nor benefit anyway, since our authorities have already done that with the silly UK only minimum age of 14.
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Miles

Esteemed Pedelecer
Nov 4, 2006
504
1
The category to which pedal assisted bicycles above 250 W and 25 km/h belong is “Mopeds”, defined as:

Two-wheel vehicles (category L1e) or three-wheel vehicles (category L2e) with a maximum design speed of not more than 45 km/h and characterized by:
The lowest category for Type/SV Approval is "Low Powered Mopeds".
- Pedals
- Max. motor power 1 kW
- Max. design speed 25 km/h

I would have thought that lobbying to raise the speed of this category to 32 km/h would be a reasonable move.......

Miles
 
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monster

Pedelecer
May 13, 2009
120
0
how will the law stand with regards to insurance and number plates on the non-exempt (more powerful) class? thats the key question.

its imposible for the individual to get a new vehicle type-approved. if a vehicle is not type-approved its impossible to get it insured. insurance companies won't insure custom made or rare vehicles.

i hope they do raise the power limits to the american standard. i would feel a lot safer keeping up with the traffic than obstricting them. it all sounds positive from what david says.
 

Mussels

Esteemed Pedelecer
Jun 17, 2008
3,207
8
Crowborough
how will the law stand with regards to insurance and number plates on the non-exempt (more powerful) class? thats the key question.

its imposible for the individual to get a new vehicle type-approved. if a vehicle is not type-approved its impossible to get it insured. insurance companies won't insure custom made or rare vehicles.

i hope they do raise the power limits to the american standard. i would feel a lot safer keeping up with the traffic than obstricting them. it all sounds positive from what david says.
I didn't think there was an American standard with some states allowing higher power than others. A bit like Europe really.
 

flecc

Member
Oct 25, 2006
53,616
30,884
how will the law stand with regards to insurance and number plates on the non-exempt (more powerful) class? thats the key question.

its imposible for the individual to get a new vehicle type-approved. if a vehicle is not type-approved its impossible to get it insured. insurance companies won't insure custom made or rare vehicles.
This isn't the case, the Single Vehicle Type Approval Scheme exists for that express purpose and a high powered e-bike can be approved as either a Low Powered Moped (up to 1000 watts and restricted to 16 mph), or a moped with no power restriction and falling into the up to 30 mph class.

This first link tells you about the scheme:

Single Vehicle Type Approval

This second link tells you the groups and fees. Scroll down to "Motorcycles" and you'll see the two top classes and the fees of £55 or £85 for those two groups appropriate to e-bikes. Insurance will be the same as that for electric mopeds, road tax free. A rear number plate will be required and MOTs after three years.

SVA groups and fees

i hope they do raise the power limits to the american standard. i would feel a lot safer keeping up with the traffic than obstricting them. it all sounds positive from what david says.
As Mussels remarked, there is no effective US standard, and some states have lower legal power limits. One state even bans e-bikes outright, though their police don't seem aware of that fortunately.
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Straylight

Esteemed Pedelecer
Jan 31, 2009
650
2
Out of interest, where would you take a high powered e-bike for an MOT? I presume there'd need to be an accredited LBS somewhere, as I can only imagine what they'd say at the local garage :D .
 

flecc

Member
Oct 25, 2006
53,616
30,884
If it's type approved as I've mentioned above, it's an MOT accredited motorcycle dealer who would do it. They already do some oddball stuff like the autocycles and cyclemotors of yesteryear.

If our government were to approve the high speed e-bike class that the EU has already approved, no MOTs woud ever be necessary.
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monster

Pedelecer
May 13, 2009
120
0
good luck geting anything to pass the Single Vehicle Type Approval Scheme. have you seen how many hurdels they make you jump? and even if you do get it done there is no insurance company that insures custom built stuff. very rare.
 

flecc

Member
Oct 25, 2006
53,616
30,884
good luck geting anything to pass the Single Vehicle Type Approval Scheme. have you seen how many hurdels they make you jump? and even if you do get it done there is no insurance company that insures custom built stuff. very rare.
There are no particular problems with SVA, and all manner of oddball vehicles have been taken through. Likewise they've found insurance too. There's even been a motorised shed, a motorised double divan bed and this motorised couch on the link below is street legal, and like all the others mentioned has been used insured on the roads. Here you see it visiting the motor show:

Motorised couch

Our roads have numerous custom built amateur vehicles on them, all with type approval and insured, so I don't know where you are getting this negativity from. Any sound roadworthy bike with a 1000 watt hub motor will sail through approval for the low powered moped class which is intended for precisely this pedalled bike purpose.

The faster moped class to permit up to 30 mph needs some more thought, but it's just commonsense. For example, use a Magura hydraulic disc front brake, equip with lights and mudguards, rig a higher intensity brake light operated from switched levers or other actuators and use decent section tyres. Add a rear number plate mounting plate and a licence holder at the LH front and that's it. Then get the type approval and see a good insurance broker who knows the two wheeler market.
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Wisper Bikes

Trade Member
Apr 11, 2007
6,341
2,297
70
Sevenoaks Kent
Meeting in Brussels

Hi Guys

Here are the proposals for changes to the laws regarding electric bikes.

I will keep you posted on developments.

All the best David


ETRA proposal on behalf of industry concerned for
the modification of the rules in Directive 2002/24/EC
governing electric cycles and mopeds


1) As for cycles with pedal assistance excluded from the scope of Directive 2002/24/EC:

On behalf of the industry, ETRA proposes to change the current definition, which is as follows:

“cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of 0.25 kilowatts, of which the output is progressively reduced and finally cut off as the vehicle reaches a speed of 25 km/h, or sooner, if the cyclist stops pedaling.”

Into the following new definition

“cycles with pedal assistance which are equipped with one or more auxiliary electric motors having a combined maximum continuous rated power of 0.50 kilowatts, of which the output is progressively reduced and finally cut off as the vehicle reaches a speed of 25 km/h, or sooner, if the cyclist stops pedaling. Such cycles shall not be considered motor vehicles.”

2) As for cycles with pedal assistance not excluded from the scope of Directive 2002/24/EC:

On behalf of the industry, ETRA proposes the introduction of a new category as a subdivision of the current category L “mopeds”. This new category would be defined as follows:

“Cycles with pedal assistance which are equipped with one or more auxiliary electric motors having a combined maximum continuous rated power not exceeding 1 kilowatts, of which the output is cut off as the vehicle reaches a speed of 45 km/h, or sooner, if the cyclist stops pedaling.”

For this category the industry is prepared to define the components and characteristics that will need to be submitted to type-approval as well as to develop the testing procedures for those components and characteristics.

3) As for cycles and low-performance mopeds with an electric

Low-performance mopeds are currently defined by means of a note to Annex I. The definition is as follows:

“Low-performance mopeds, i.e. mopeds with pedals, with an auxiliary engine of power not exceeding 1 kW and a maximum design speed not exceeding 25 km/h”

On behalf of the industry, ETRA proposes the introduction of a new category as a subdivision of the current category L “Mopeds”. This category would be defined as follows:

“Cycles and mopeds with an electric motor of power not exceeding 1 kW and
a maximum design speed not exceeding 25 km/h.”

For this category the industry is prepared to define the components and characteristics that will need to be submitted to type-approval as well as to develop the testing procedures for those components and characteristics.
 

monster

Pedelecer
May 13, 2009
120
0
what do they mean by "Maximum continuous rated power output of the motor shall not exceed" ?

it sounds like you can have any peak power you want, so long as it melts at above 200w continuous? ride time and motor size are a major factor here. i could make a 200w motor do peaks of 1000w for a short ride but it would be increadibly hot after about 3 miles. if you have a physically large motor it will take a longer time to heat up and cool down because of its heat capacity.
 

monster

Pedelecer
May 13, 2009
120
0
look at the problems this guy had getting his bike type approved. Golden Eagle cyclemotor them phone up some insurance companies and ask them to insure this bike. i tried to go down this route last year it's just not possible. its a full time job getting a vehicle through the single vehical type approval.