What extra testing needs to be carried out by the VCA to grant L1e-A type approval for a throttle controlled 250W rated powered cycle for conversion from an existing UK defined 250W EAPC which already meets the existing EN15194 safety standard?

“Furthermore, the Commission explicitly stated that open throttle bicycles up to 25 km/h would be classified as L1e-A vehicles. Before this statement, the Commission had indicated that L1e-A was meant for pedal assisted cycles 25 km/h up to 1 kW only. Categorization of open throttle bicycles as L1e-A not only frees these vehicles from factor 4 but also results in additional benefits. The vehicles will enjoy all adapted requirements for electric cycles as well as exclusion from a few additional requirements, i.e. mirrors and driver-operated controls (including identification of controls, tell-tales and indicators).”

Which means the only difference is a throttle and that speed is limited to 25 kph and nominative power to 1 kW.

That quote from 2013 may not still stand as the agreement with ETRA was dropped from the regulation after ETRA was closed down although Annick Roetynck now with AVERE LEV has questioned its removal, I can find no follow up as to whether it has been reinstated.

Edited December 9, 201510 yr by shemozzle999

I don't think there's anything definitive yet on this issue. We still seem to only have the 2013 draft for the type approval of L1e-A and L1e-B and from some statements that also appears to have been changed in certain details.

 

The most important thing to note is the recent introduction of a group Q driving licence for L1e-A, and the fact that L1e-A is a motor vehicle. Those things indicate registration and insurance will be necessary, and for those to be administered a number plate will be necessary. That conflicts with the draft type approval which specified no number plate space required for L1e-A.

 

There's also the little matter of MOTs which apply to all motor vehicles. All in all I cannot see how a pedelec with throttle can be type approved as L1e-A and still avoid considerable bureaucracy. Therefore I doubt the DfT are correct in saying they can be treated equally as pedelecs without other changes in the laws being implemented.

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Here is the letter from AVERE to the Commission think I it confirms your suspicions regarding twist and go throttles:

 

https://circabc.europa.eu/sd/a/55b5d416-aa35-4edb-9a1c-6092af7ff57a/03.c.4%202015_04_13_Letter_Avere.pdf

Thanks Shemozzle, their reaction to the EC reply seems similar to my disbelief at the DfT ruling. Statements are being made which simply cannot accord with current law or current type approval intentions.

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So currently as things stand L1e-A still requires rider input, i.e. no twist and go, but the the increased power level permits practical commercial cargo usage but no speed advantage for commuter usage.

 

L1e-B allows twist and go but comes with all the moped restriction baggage.

So what we need now is clarification on:

 

1) The L1e-A low powered moped type approval requirements.

 

2) Where twist and go pedelecs stand with regards to L1e-A type approval requirements,

 

3) Does there really have to be pedal input to have power in L1e-A mopeds? If so this is not the replacement class for the Low Powered Mopeds, since those did not have to have pedal input. Making those L1e-B if they have open throttles is surely too draconian for a 15.6 mph vehicle? A full moped licence to ride at that speed would be ridiculous and make the class just at redundant as the Low Powered Moped class has been, with no takers again.

 

I still think this whole issue is far from clear, with each piece of news the mess appears to grow.

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Edited December 10, 201510 yr by flecc

It also sounds as if only torque devices are allowed for L1e-A if it has to meet the factor 4 testing, so no cadence only option.

Edited December 10, 201510 yr by shemozzle999

I think we need to watch this very carefully, because it's looking to me like L1e-A is our existing EAPC. I'm probably being paranoid, but this is how I see it: To be classed as a pedal cycle an EPAC will have to be Type Approved, that reduces the EPAC class to a whitelist of specific models which have been submitted for testing by the manufacturer. Anything else (kits, homebuilds, non-approved models) will not be road legal. The only process for making them road legal would be SVA, for which the minimum standard will be L1e-A. So the majority of electrically assisted cycles will become "motor vehicles", requiring registration, insurance, licensing etc. The provision of a new license group suggests they don't expect L1e-A to be the footnote "Low-Powered Mopeds" currently are. It's not just about throttles.

 

Don't expect them to approve any helmet standard other the current motorcycle one either. After all motorcycle helmets are required on mopeds which can't exceed 30mph, something which pedal cycles comfortably do given a downward slope.

 

Of course you can claim your EAPC was built before 2016, but with no registration or recording of frame numbers (might not even be a frame number), how do you prove it? "Innocent until proven guilty" has a habit of turning it "guilty unless you can prove you qualify for the exemption".

Here is the letter from AVERE to the Commission think I it confirms your suspicions regarding twist and go throttles:

 

https://circabc.europa.eu/sd/a/55b5d416-aa35-4edb-9a1c-6092af7ff57a/03.c.4 2015_04_13_Letter_Avere.pdf

By "without pedal assistance" do they perhaps mean, or think they mean, scooter type vehicles which lack pedals altogether?

I think you are being overly pessimistic despite my having a first hand experience of British bureaucracy, indigenous and exported variety. The EU regulation is predominant (for the moment, if my reading of the news is correct...) and would always hold up in court. You could argue that the bike is conform to EU regulations so you are able to ride it in any member state.

 

L1e-A is different only by motor nominative power limited to 1 kW. As long as you stay with 250 W nominative you are a bicycle not a moped.

 

Next year when you leave the EU I will burn a candle for you...

The EU regulation is predominant (for the moment, if my reading of the news is correct...) and would always hold up in court. You could argue that the bike is conform to EU regulations so you are able to ride it in any member state.

 

L1e-A is different only by motor nominative power limited to 1 kW. As long as you stay with 250 W nominative you are a bicycle not a moped.

 

The EU law is paramount of course and we know that. But you are misunderstanding the changes taking place that we are discussing, they are EU ones.

 

The L1e-A Type Approval measures will apply to 250 watt pedelecs with full throttles, and they are obviously not being considered as bicycles if they have to have motor vehicle type approval. If you read the letter in the link in this post you'll see the same concern expressed, type approval required but no means provided to get it. That's a ban in any other words.

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I think we need to watch this very carefully, because it's looking to me like L1e-A is our existing EAPC.current motorcycle

 

That is not so with pedelecs which are specifically excluded from Motor Vehicle Type Approval. It's the full throttle pedelecs whch are subject to that type approval with effect from January 1st 2016, but the DfT says they will still be consider them as EAPCs as long as all the other factors comply witn pedelec exemption conditions.

 

The problem for full throttle pedelecs is that there is no known way to type approve at present, and that is our concern.

.

Gents, please don't take this then wrong way..... But I've been a member and ebike enthusiast for nearly 5 years......once I had a handle on legality but I'm lost now

 

And for most of that time I've been Technically illegal ( ie I was 250w when uk limit was 200w vs EU 250w) not dft said they wouldn't prosecute EU legal bikes

 

Now I'm 250w which is now legal in line with EU but i have a throttle , so probably illegal in 2016 (ignoring grandfather rights)

 

So what, for newbies as much as me, is the realty ?

 

Am I ok with 250w and throttle if I buy in 2016

 

Forget the detail- I'm a just a new buyer...... What is ok ?

So what, for newbies as much as me, is the realty ?

 

Am I ok with 250w and throttle if I buy in 2016

 

Forget the detail- I'm a just a new buyer...... What is ok ?

 

An new e-bike with an independent acting throttle will not be a pedelec in law in 2016, so is a motor vehicle.

 

The DfT have said that they will still consider one to be an EAPC in the UK, so long as all other aspects match pedelec law.

 

But their proviso is, since that conflicts with mandatory EU motor vehicle type approval law, it must be type approved. The problem now is that we don't appear to have any way of doing that, so this needs resolution.

 

Meanwhile, in 2016 only a true pedelec will be legal.

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Edited December 10, 201510 yr by flecc

Avere LEV-TF seems the only EU organization battling for throttle usage for powered cycles EU wide.

 

I don't know if BEBA contacted them last year or if any communications were forthcoming from this Pedelec news article:

 

http://www.pedelecs.co.uk/news/light-electric-task-force-replaces-etra/

 

On further digging through the EU trade association COLEBI, who appears to have the ears of the Commission, opposed the idea as stated in the letter mentioned earlier in this thread, not entirely surprised as it boasts most of the major EU producers as members, but was surprised to find out that BAGB was also a member.

 

Draft meeting minutes of the

Motorcycle Working Group MCWG / MVEG on Motorcycles

(L-category vehicles)

 

https://circabc.europa.eu/sd/a/8e2993c5-f501-41ec-a77a-7c20e15e25ca/2015_04_14_MCWG_L_Cat_v1.pdf

 

contains this proposed opposing amendments from AVERE and COLEBI:

 

https://circabc.europa.eu/d/a/workspace/SpacesStore/04aab4c9-600a-4b4a-9186-b9576079ed22/6b2_AVERE Comments - SR1 and RE3.pdf

 

https://circabc.europa.eu/d/a/workspace/SpacesStore/2547c0d8-2b42-41bc-92df-8f8daeee299e/6b3_CONEBI's Position for the EU COM' s 2 proposals to the UNECE 16 Feb 2015.pdf

 

I concluded that COLEBI's amendment would scupper Claire Rees inclusion of L1e-A type approved vehicle to be as treated as EAPC's as the L1e-A amendment would not comply with the definition of an EAPC i.e. power >250W.

 

As BAGB is a member of COLEBI and some former members of BEBA are members of BAGB I would like to know if they support this COLEBI amendment as I had previously assumed their view to be different.

 

I also noted she was in attendance of the meeting but was concerned about number plate sizes.

 

I have not managed to find any information on the latest 22 September 2015 meeting.

 

Edited to include MCWG document links

Edited December 11, 201510 yr by shemozzle999

Updated post above.

 

September meeting

 

https://circabc.europa.eu/w/browse/1332e72a-27f0-455d-9a15-d2b8a93c3c53

 

 

Minutes:

 

https://circabc.europa.eu/sd/a/c193325b-5e6f-4b00-956f-723a8bac2f00/2015_09_23_MCWG_L_Cat_v3.pdf

 

 

next meeting 15 December 2016 - next Tuesday!

 

https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp?FormPrincipal:_idcl=FormPrincipal:_id4&FormPrincipal_SUBMIT=1&id=13129bb7-3bf3-462f-895a-7a817bdebd0d&javax.faces.ViewState=rO0ABXVyABNbTGphdmEubGFuZy5PYmplY3Q7kM5YnxBzKWwCAAB4cAAAAAN0AAEycHQAKy9qc3AvZXh0ZW5zaW9uL3dhaS9uYXZpZ2F0aW9uL2NvbnRhaW5lci5qc3A=

 

 

Link to list of meetings - past to present:

 

https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp?FormPrincipal:_idcl=navigationLibrary&FormPrincipal_SUBMIT=1&org.apache.myfaces.trinidad.faces.STATE=DUMMY&id=08880174-18dd-4b1e-80e4-20d488f64231

 

 

Edit links updated

Edited December 11, 201510 yr by shemozzle999

Thanks for all this Shemozzle, the L1e-A type approval situation really is a last minute shambles.

 

I think COLEBI meant well with their amendments and it's good that they've included provision for the S class, but stating 250 watts and 1000 watts was not a good idea. At the very least it should be clearly stated as two separate classes, but I wonder if language difficulties came into this, them meaning or rather than and.

.

I prefer the more future forward thinking of Avere - if the throttle argument can't be lowered to apply to L1e-A then disadvantaged members will not have any choice after Jan 2016.

]

if the throttle argument can't be lowered to apply to L1e-A then disadvantaged members will not have any choice after Jan 2016.

 

I hope i'm wrong, but I've felt all along that this will probably be the outcome. Since the EU hasn't had throttles since 1999, in effect ever, since e-biking hardly existed before that, I don't think they even understand our obsession with them on EAPCs.

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Now I am confused!!!!!!!!

 

 

From meeting 25 September:

 

https://circabc.europa.eu/sd/a/2c528e2d-7073-4da4-97a0-ee0480170f33/5c5_Codecision_168_2013_Errors_Comments_Questions_list_v5.xlsx

 

Question16 in the spreadsheet:

 

Belgium question:

 

How to classify a powered cycle equipped with throttle control (accelerating up to and/or maintaining a vehicle speed up to and including 25 km/h without pedalling) ?

 

Reply:

 

Power assisted pedal cycles ≤ 250W and cut-off speed ≤ 25 km/h without throttle control (i.e. no pedalling = no power) are not in the scope of Reg 168/2013 and consequently in the scope of the Machinery Directive 2006/42/EC. However, such cycle type equipped with a throttle, or with a higher power, or with a higher cut-off speed fall within the scope of Reg 168/2013 and is to be categorised as an L1e category vehicle. It does not matter if the throttle is only used as launch control or used to accelerate to a certain target vehicle speed. The only relevant criterion is pedalling yes or no.

 

Pedal cycles ≤ 1000W and cut-off speed ≤ 25 km/h with throttle control are therefore in the scope of 168/2013 and are to be categorised as a L1e-A powered cycle. Powered cycles without throttle control 250 W < continuous rated power ≤ 1000W and cut-off speed ≤ 25 km/h are also to be classified as L1e-A powered cycles.

 

This is justified as the "primary aim" allows for a 'secondary aim', which might be a throttle controlled operated mode.

 

In our view the maximum cut-off vehicle speed (≤ 25 km/h) and maximum power (≤ 1000W) are the functional-safety critical classification criteria of category L1e-A. In case one or both of these critical criteria will be exceeded the powered cycle is to be classified as a L1e-B moped in

accordance with Art 4(4a) of Reg 168/2013 and the associated more stringent safety

requirements shall apply, independent if the vehicle is equipped with throttle control or not.

Power assisted pedal cycles ≤ 250W and cut-off speed ≤ 25 km/h without throttle control (i.e. no pedalling = no power) are not in the scope of Reg 168/2013 and consequently in the scope of the Machinery Directive 2006/42/EC. However, such cycle type equipped with a throttle, or with a higher power, or with a higher cut-off speed fall within the scope of Reg 168/2013 and is to be categorised as an L1e category vehicle. It does not matter if the throttle is only used as launch control or used to accelerate to a certain target vehicle speed. The only relevant criterion is pedalling yes or no.

 

Pedal cycles ≤ 1000W and cut-off speed ≤ 25 km/h with throttle control are therefore in the scope of 168/2013 and are to be categorised as a L1e-A powered cycle. Powered cycles without throttle control 250 W < continuous rated power ≤ 1000W and cut-off speed ≤ 25 km/h are also to be classified as L1e-A powered cycles.

 

The wording is a bit muddled, but I'm sure they basically mean that pedelecs are in the clear, and also pedelecs with a throttle that is only active while pedalling or pedal thrusting from a standstill are in the clear, remaining as bicycles.

 

Those with a throttle that acts without pedalling or pedal pressure are motor vehicles and need to be approved as L1e-A.

 

That leaves the question of what L1e-A type approval will require. Hopefully that will prove to be minimal.

 

But of course L1e-A requires a group Q or better driving licence, so we are dependent on the DfT telling us how full throttle pedelec riders can avoid that.

 

Once again I take the gloomy view. At present I see no way in which a full-acting-throttle pedelec can avoid full L1e-A type approval and a group Q driving licence. Further implications of this are registration, number plate, insurance, compulsory helmet, MOTs.

 

I see us having to accept the EU situation of pedelecs only in future, unless the DfT really sticks it's neck very far out and flaunts EU law. It's difficult to see that happening.

.

It reads as if they have created 2 L1e-A types - a low powered cycle and a high powered cycle - logically shouldn't they have there own type approvals based on safety requirements or split them into A and B types and promote the old B type to C type. That would give them some wriggle room but they seem reluctant to alter the original 168/2013 regulation.

 

The only problem with that would be how they would justify how the addition of a throttle to what is effectively an identically specified EPAC has altered the safety requirement to deem type approval necessary.

Edited December 12, 201510 yr by shemozzle999

It reads as if they have created 2 L1e-A types - a low powered cycle and a high powered cycle - logically shouldn't they have there own type approvals based on safety requirements or split them into A and B types and promote the old B type to C type. That would give them some wriggle room but they seem reluctant to alter the original 168/2013 regulation.

 

The only problem with that would be how they would justify how the addition of a throttle to what is effectively an identically specified EPAC has altered the safety requirement to deem type approval necessary.

 

It's the power without pedalling that's the problem, 168/2013 excludes exemption. That leaves only L1e-A for such a bike.

 

As you say they don't want to alter 168/2013, which in this respect has existed since 2003 in the original type approval regulation 2002/24/EC. I think their attitude is probably that if it's been ok for all that time, why is there need to change it,

 

Hence my gloomy view of our prospects for realistically having independent throttles without impossible bureaucracy.

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Edited December 13, 201510 yr by flecc