November 5, 201411 yr Trex, VOSA and DVLA are quite clear that there is no requirement to display a numberplate on speed pedelecs in the UK. Only because there is no regulation permitting S class e-bikes in the UK. Once and if we get a regulation permittig them, there will no doubt be restrictions. They will certainly require insurance which in turn automatically means number plates as a means of control. That is unavoidable. .
November 5, 201411 yr I am against the unlimited weights for several reasons.. 1. There are a number of e-mopeds currently for sale that the sellers claim only have 200 watt motors and weigh 39 KGs,therefore these are bicycles and qualify as pedelecs. I recognise one of those scooters,it weighs 90 KGs and has an 800 watt motor but the seller claims 200 watts. The police find it very difficult to determine the power of a motor but weight can be easily checked,remove the weight limits and every one of these motorbikes will,with a 200 watt sticker on the motor be bicycle legal,the Dutch have just banned mopeds from cycle tracks,we could be opening the possibility of such machines having access to all our cycle tracks. 2. The 250 watt and 40 kilo limits promotes the design of lighter bikes,I think e-bikes are generally nicer to ride if the weight is down to 20 kilos or less,especially if you want to ride the bike unassisted at times. So,nice the power is in line with Europe at 250 watts,nice that throttles are to be legal,albeit with type approval complications but I like the 40 kilos weight limit and will write to the D f T accordingly. Am not against these e-mopeds,I think the bike 'Nicom' is a wonderful little moped,sold under the Sachs name in Germany and should have an easy and inexpensive means of registering/taxing/insuring but they should be motor vehicles not bicycles,road use only. KudosDave
November 5, 201411 yr I like the 40 kilos weight limit and will write to the D f T accordingly. When writing Dave, can you make clear that you are happy with no weight limit on e-tricycles. I would hate to see a continuation of the very restrictive 60 kilo limit for those, preventing anyone having an e-rickshaw. No country in mainland Europe finds that's necessary. .
November 5, 201411 yr I believe that the regulations are relying on everyone obeying the rules by including the provision to fine offenders throughout the entire selling chain, including approval testing providers and also have included the power to revoke type approval if they don't.
November 5, 201411 yr When writing Dave, can you make clear that you are happy with no weight limit on e-tricycles. I would hate to see a continuation of the very restrictive 60 kilo limit for those, preventing anyone having an e-rickshaw. No country in mainland Europe finds that's necessary. . Flecc,isn't 60 kilos enough to produce an e-rickshaw? If not,these would surely be admissible as a commercial product licensed by the the local council,used like a London cab....which has many exemptions to keep it convenient. When I spoke to Andrew of Oxygen,who manufactures e-rickshaws he said the biggest problem to selling them wasn't technical it was politics by the taxi lobby fighting them being licensed by councils,very successfully keeping them out of most cities. KudosDave Edited November 6, 201411 yr by Kudoscycles
November 6, 201411 yr I believe that the regulations are relying on everyone obeying the rules by including the provision to fine offenders throughout the entire selling chain, including approval testing providers and also have included the power to revoke type approval if they don't. But the regs under EAPC should currently stop these motorbikes being allowed as bicycles but the reality is that even now trading standards have no means of determining what is a motorbike and what is a bicycle. Actually thinking more about my own recent post I cannot see any point of having a class for S Pedelecs. If S Pedelecs have to be registered/taxed/insured/helmet then why not go the whole hog and buy an e-moped. The e-moped is often cheaper,they could have 800 watts not 350 watts,they would have more carrying capacity,they could have better weather protection,they would have more road presence,they could carry a pillion passenger/shopping,integral box for helmet and have a throttle.It is surprising that members on this forum have not looked at the legal e-scooter or e-moped in preference to the illegal S class bicycle? That would mean an easy choice,you either select an EN15194 spec bicycle which can ride anywhere or an e-moped which rides on the road. Looked at that way the S pedelec doesn't have a place,it cannot be used on cycle tracks but lacks the power and adaptability of a e-moped...perhaps others can explain the purpose of an S pedelec ? KudosDave
November 6, 201411 yr I am against the unlimited weights for several reasons.. 1. There are a number of e-mopeds currently for sale that the sellers claim only have 200 watt motors and weigh 39 KGs,therefore these are bicycles and qualify as pedelecs. I recognise one of those scooters,it weighs 90 KGs and has an 800 watt motor but the seller claims 200 watts. The police find it very difficult to determine the power of a motor but weight can be easily checked,remove the weight limits and every one of these motorbikes will,with a 200 watt sticker on the motor be bicycle legal,the Dutch have just banned mopeds from cycle tracks,we could be opening the possibility of such machines having access to all our cycle tracks. 2. The 250 watt and 40 kilo limits promotes the design of lighter bikes,I think e-bikes are generally nicer to ride if the weight is down to 20 kilos or less,especially if you want to ride the bike unassisted at times. So,nice the power is in line with Europe at 250 watts,nice that throttles are to be legal,albeit with type approval complications but I like the 40 kilos weight limit and will write to the D f T accordingly. Am not against these e-mopeds,I think the bike 'Nicom' is a wonderful little moped,sold under the Sachs name in Germany and should have an easy and inexpensive means of registering/taxing/insuring but they should be motor vehicles not bicycles,road use only. KudosDave Couple of good points there which it takes someone in the trade to think through. Although if a seller is going to ignore the rules so blatantly, it doesn't really matter how those rules are framed.
November 6, 201411 yr But the regs under EAPC should currently stop these motorbikes being allowed as bicycles but the reality is that even now trading standards have no means of determining what is a motorbike and what is a bicycle. Actually thinking more about my own recent post I cannot see any point of having a class for S Pedelecs. If S Pedelecs have to be registered/taxed/insured/helmet then why not go the whole hog and buy an e-moped. The e-moped is often cheaper,they could have 800 watts not 350 watts,they would have more carrying capacity,they could have better weather protection,they would have more road presence,they could carry a pillion passenger/shopping,integral box for helmet and have a throttle.It is surprising that members on this forum have not looked at the legal e-scooter or e-moped in preference to the illegal S class bicycle? That would mean an easy choice,you either select an EN15194 spec bicycle which can ride anywhere or an e-moped which rides on the road. Looked at that way the S pedelec doesn't have a place,it cannot be used on cycle tracks but lacks the power and adaptability of a e-moped...perhaps others can explain the purpose of an S pedelec ? KudosDave As I understand it, if a product is found to be outside the specification of its specified type approval it will automatically be placed in the next class above and the supply chain would then be liable to any fines dictated by the member state in which it was placed on the road, so the end seller and supply chain would be liable for making it available and the end buyer would have a strong case should they suffer at the hands of the law for using it without the knowledge that it didn't comply.
November 6, 201411 yr .perhaps others can explain the purpose of an S pedelec ? KudosDave Because some of us would like the option of a bit more speed but be able to pedal when we want to and appreciate that a S ped would be lighter and less bulky than a e moped. I be quite happy if they were restricted to a 350w motor and a 25mph limit. Even if that means moped type regulations having to be applied.
November 6, 201411 yr Flecc,isn't 60 kilos enough to produce an e-rickshaw? Nowhere near enough Dave, pedicabs generally weigh very much more, given the strength necessary to make them safe with three or four of any weight on board. The type of very high torque but legal motor they need, such as the heavy Lynch, is best served by adequate lead acid batteries which only adds to the weight. For a working day the batteries must be able to have more than the hour or two of running capacity that our e-bikes have. A typical motorised pedicab example weighs 145 kilos. Our regular legal e-bike motors and batteries of any kind aren't remotely adequate, for example the van body equivalent of one of these rickshaws is rated as 5 cwt / 250 kilos payload alone. Despite the truth about the London taxi drivers opposition, it's the weight law that's being used to get the police to act. Without that they'd be powerless to object on legal grounds to such as I've described. .
November 6, 201411 yr if e-mopeds are legal, there could be the kind of motorbike taxis where the paying customers sits pillions behind the rider. I've seen them in Asia. That'll beat the congested London traffic. http://cdn.greenpacks.org/wp-content/uploads/2012/12/scooter1.jpg
November 6, 201411 yr if e-mopeds are legal, there could be the kind of motorbike taxis where the paying customers sits pillions behind the rider. I've seen them in Asia. That'll beat the congested London traffic. http://cdn.greenpacks.org/wp-content/uploads/2012/12/scooter1.jpg Practical where riding without helmets is allowed, as in this example Trex. But not here. Anyway, the London pedicabs are a tourist market attraction, needing to carry two or three passengers. .
November 6, 201411 yr Because some of us would like the option of a bit more speed but be able to pedal when we want to and appreciate that a S ped would be lighter and less bulky than a e moped. I be quite happy if they were restricted to a 350w motor and a 25mph limit. Even if that means moped type regulations having to be applied. Would you be happy to have road use only? No promenades,no cycle tracks,no bridleways? With good design I think it may be possible to make an e-moped in the style of a bicycle but with 350 or even 500 watt power and 30 mph speed. But the feedback I get from customers is they want to use it everywhere they could use a bicycle and that is not possible,to be legal you would have to make a choice. I think the market for such a mongrel would be very small. KudosDave
November 6, 201411 yr Would you be happy to have road use only? No promenades,no cycle tracks,no bridleways? With good design I think it may be possible to make an e-moped in the style of a bicycle but with 350 or even 500 watt power and 30 mph speed. But the feedback I get from customers is they want to use it everywhere they could use a bicycle and that is not possible,to be legal you would have to make a choice. I think the market for such a mongrel would be very small. KudosDave I would be interested even it meant road only for commuting purposes I'd have two bikes then - one "mongrel" and one pedelec for leisure But I don't doubt you are right about market size. Tiny
November 6, 201411 yr Author But I don't doubt you are right about market size. Tiny I'm not so certain... what's the UK market size for mopeds/scooters? ...their regulatory requirements are far more onerous than those for speed pedelecs, and speed pedelecs with a throttle can do almost everything better than a scooter can do in town, no?
November 6, 201411 yr ok, well thats our submission submitted Pretty much in agreement with KudoDave.. all looks ok, but we can't see why you'd want to remove the weight limit. There is no way some of the eMopeds on ebay should be classed as pedelecs. The weight factor is an important part of it being a bike in our opinion.
November 6, 201411 yr I don't see the weight limit removal as a problem, mainland Europe seem to manage well without problems and they can have e-pedicabs that are actually practical and legal. .
November 6, 201411 yr I'm not so certain... what's the UK market size for mopeds/scooters? ...their regulatory requirements are far more onerous than those for speed pedelecs, and speed pedelecs with a throttle can do almost everything better than a scooter can do in town, no? James....you are confusing us all and I think confusing yourself. Firstly,it is not possible to legally use an S pedelec as anything in the UK. I think we are all agreed it cannot be a bicycle because of the power and speed. I spoke to my friends at SVA and there are so many mods needed to make it into a moped,if you went through the obstacles,would you want to wear a crash hat on what still looked like a bicycle,albeit one with motorbike headlights,indicators etc? Unless you have some magic bit of documentation trying to make an S pedelec into anything legal is a none starter. Whereas there are many e-mopeds that already have type approval,they can be readily registered without recourse to SVA.....to prove it I will bring over an e-moped next shipment and register it,just to prove the point. But I would be pleased if you could do the same to an S pedelec, there are many on this forum who would love to know the process? KudosDave
November 6, 201411 yr I would be interested even it meant road only for commuting purposes I'd have two bikes then - one "mongrel" and one pedelec for leisure But I don't doubt you are right about market size. Tiny Kirsten....just out of interest would an e-moped be of interest to you? Maybe it is too far away from a bicycle in appearance? Maybe having to pay registration costs and insurance takes away the low cost of a bike?,you would have to tax it but this is free cost. Am interested in reasons why these bikes are not as numerate as they are in Germany or Holland,maybe they are just not so available or off our radar. KudosDave
November 6, 201411 yr When writing Dave, can you make clear that you are happy with no weight limit on e-tricycles. I would hate to see a continuation of the very restrictive 60 kilo limit for those, preventing anyone having an e-rickshaw. No country in mainland Europe finds that's necessary. . But again shouldn't an e-rickshaw be classed as a motor vehicle, for road use only? If they were classed as an e-bike you could end up with e-rickshaws being allowed on paths and off-road tracks which would be both very bumpy for the passengers and rather damaging for the trails! I'd be more in favour of a road-only class of e-bikes which could cover S-pedelecs as well as e-rickshaws. Michael
November 6, 201411 yr I'm not so certain... what's the UK market size for mopeds/scooters? ...their regulatory requirements are far more onerous than those for speed pedelecs, and speed pedelecs with a throttle can do almost everything better than a scooter can do in town, no? Under the new regs can we have s class bikes with throttles?
November 6, 201411 yr Would you be happy to have road use only? No promenades,no cycle tracks,no bridleways? With good design I think it may be possible to make an e-moped in the style of a bicycle but with 350 or even 500 watt power and 30 mph speed. But the feedback I get from customers is they want to use it everywhere they could use a bicycle and that is not possible,to be legal you would have to make a choice. I think the market for such a mongrel would be very small. KudosDave As a London Commuter yes I have no problem of it being rd only. Most of my journeys are by road and on main roads a bit more speed would be an advantage.
November 6, 201411 yr But again shouldn't an e-rickshaw be classed as a motor vehicle, for road use only? If they were classed as an e-bike you could end up with e-rickshaws being allowed on paths and off-road tracks which would be both very bumpy for the passengers and rather damaging for the trails! I'd be more in favour of a road-only class of e-bikes which could cover S-pedelecs as well as e-rickshaws. Michael That isn't in question Michael, rickshaws are far too cumbersome to be used in that fashion. They are used in central city areas over short distances for taxi work. Typically a Lynch powered e-rickshaw weighs 140 kilos or more without anyone on board and has a top speed around 8 mph. They are too wide to use on such paths and off road tracks and no-one would ever use one for such leisure riding, they are just too tough to pedal assist except on smooth flat roads. So effectively they are road use only. .
November 7, 201411 yr Author As I understand it, if a product is found to be outside the specification of its specified type approval it will automatically be placed in the next class above and the supply chain would then be liable to any fines dictated by the member state in which it was placed on the road, so the end seller and supply chain would be liable for making it available and the end buyer would have a strong case should they suffer at the hands of the law for using it without the knowledge that it didn't comply. That's inline with what Trading Standards have told me - the liability does not stop with the retailer. In the case of e-bikeshop modifying Haibikes, Raleigh UK, WinoraGMBH, and Accell.BV may also be liable as they have been fully aware of e-bikeshop promoting and selling modified e-bikes for over a year. Edited November 7, 201411 yr by james@justebikes.co.uk
November 7, 201411 yr Under the new regs can we have s class bikes with throttles? You are trying to reach to the moon....Firstly, it is highly unlikely we will have S class in the UK....Secondly,the biggest market for S class is Germany,where throttles are specifically banned....Thirdly,even if we had S class in the UK no bike producer would seek type approval just for the UK,the bikes would be made to the German spec,that is without throttles. The latter is already having an effect,no German manufacturer will fit a throttle and any chinese manufacturer who's biggest market is Germany is also reluctant to fit throttles. Also those companies which sell in the UK but get their EN15194 because the product is also sold in Germany will find it difficult and expensive to have a different EN15194 approval just for the UK spec. Even though the DfT is proposing throttles,the more prestigious (read that as bigger)suppliers will probably not fit them,retrofitting just for the UK also has its difficulties. Sorry KudosDave
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