People for Bikes Presents 3-Class as "Voluntary" to the CPSC

[Ebiker01]

around here, bike lanes are constantly interrupted by doors, deliveries, ubers, turns, pedestrians, scooters, etc etc etc

Same here , Ny/Nj area , even squad cars quite often ! Probably in every state here in the US there is a lot of “street furniture “in the bike lanes.

 

[m@Robertson]

Same here , Ny/Nj area , even squad cars quite often ! Probably in every state here in the US there is a lot of “street furniture “in the bike lanes.

On my way home from work today some jackass was facing directly away from me, trying to fly his freaking kite. Just standing right in the effing middle of the lane with the kite on the ground in front of him while he goofed with the string. Oh and he had earbuds in. I wanted to run him over on general principles.

The issues to be concerned about that need the most improvement - in my opinion which nobody asked for - all have nothing to do with the occasional cyclist that frequents a bike lane. They all have to do with the people and things surrounding the lane, and the cyclists. You want to make a safe lane? Leave the cyclists alone. All of them. Instead, encourage them. All of them. So there will be sufficient numbers in your/our group to make a difference at the next city council meeting etc. Attacking our own no matter how well intentioned is aiming at the wrong target and only helps to continue to hold us back.

By the way this includes taking shots at the CPSC and government agencies who are helping the cause. They don't need ankle-biters and neither does the cycling community.

 

[mschwett]

Same here , Ny/Nj area , even squad cars quite often ! Probably in every state here in the US there is a lot of “street furniture “in the bike lanes.

I've been finding it very interesting to ride all around northern california, observing the different patterns of bike accomodationg. While San Francisco and Oakland/Berkeley probably have the most aggressive bicycle advocacy and visible recent bike infrastructure, in many cases urban core bike lanes are just paint, frequently interrupted by a million things, starting and stopping at random. Of course the blocks are very short, with lots of intersections (typically every 200-500 feet in most american core cities) and four ways stops or signals at every one. This makes heavy high speed vehicles in the bike lane seem like a bad idea to me, both in theory and experience.

And then you go to a newer, less pedestrian friendly suburb with big wide streets, huge intersections with extremely long signal cycles in every direction, and a higher chance of a completely separate bike lane with no street parking, and higher speeds make sense. Of course, it isn't actually any faster to get anywhere because everything is much further apart and the lights are sooooooooooooo long if you miss a few, add 5 minutes to your 10 minute ride!

 

[Ken M]

This is pretty much the only needed “law” and the vast majority of people on ebikes are doing just that.

Study data shows that over 90% of riders will hit upwards of 30mph on most rides. This is because they are including down hill top speeds but that is still what I consider relevant data for establishing assist performance of an ebike. The federal definition is good in this regard. It allows for motor alone (ie a throttle) to sustain 20mph and additional speed is achieved by rider power being added to that limit on motor alone power above 20mph. That makes perfect sense to me as an ideal way to control ebike speeds instead of the People for Bikes assist cut-offs which no one likes (everyone calls it the wall effect because when the assist cuts off at 20mph all of sudden going faster requires a big effort. The federal definition would be the selected programming on every ebike sold if customers were given a choice.

Keep in mind People for Bikes claims to be a bike advocacy group yet they promote a legislation that is horrible compared to the original federal definition written by Dr. Currie back in 2001.

 

[mschwett]

On my way home from work today some jackass was facing directly away from me, trying to fly his freaking kite. Just standing right in the effing middle of the lane with the kite on the ground in front of him while he goofed with the string. Oh and he had earbuds in. I wanted to run him over on general principles.

The issues to be concerned about that need the most improvement - in my opinion which nobody asked for - all have nothing to do with the occasional cyclist that frequents a bike lane. They all have to do with the people and things surrounding the lane, and the cyclists. You want to make a safe lane? Leave the cyclists alone. All of them. Instead, encourage them. All of them. So there will be sufficient numbers in your/our group to make a difference at the next city council meeting etc. Attacking our own no matter how well intentioned is aiming at the wrong target and only helps to continue to hold us back.

By the way this includes taking shots at the CPSC and government agencies who are helping the cause. They don't need ankle-biters and neither does the cycling community.

A kite OMG. Why on earth was he flying a kite from the bike lane lol. Was it upwind from a park or something?!?!

Agreed that encouraging more people to bike is priority number 1. Infrastructure is the most needed thing to achieve that. I do think it's important to quiet the voices of the most rabid on both sides of the debate, since the extreme opinions tend to be used as illustration of why the "bike fanatic" or "anti-bike fanatics" shouldn't be listened to. We certainly had our fair share of that here with the very bad behavior of a small number of people on both sides creating a lot of unneccesary friction between drivers and cyclists.

 

[Ken M]

On my way home from work today some jackass was facing directly away from me, trying to fly his freaking kite. Just standing right in the effing middle of the lane with the kite on the ground in front of him while he goofed with the string. Oh and he had earbuds in. I wanted to run him over on general principles.

The issues to be concerned about that need the most improvement - in my opinion which nobody asked for - all have nothing to do with the occasional cyclist that frequents a bike lane. They all have to do with the people and things surrounding the lane, and the cyclists. You want to make a safe lane? Leave the cyclists alone. All of them. Instead, encourage them. All of them. So there will be sufficient numbers in your/our group to make a difference at the next city council meeting etc. Attacking our own no matter how well intentioned is aiming at the wrong target and only helps to continue to hold us back.

By the way this includes taking shots at the CPSC and government agencies who are helping the cause. They don't need ankle-biters and neither does the cycling community.

I fully support the CPSC federal definition for the best adoption potential of ebikes in the US. I'm sorry I am not going to say nice things about People for Bikes given that I did reach out to them and attempted to have a conversation about the 3-class model legislation and they petty much told me they were the experts and I had nothing to add. We'll I petitioned the CPSC to preempt their work for the past 5+ years so maybe they'll find out I did have something to add.

Let me give you an example of brain dead policy. They suggest that class 3 ebike be restricted to use on street and road side bike lanes. A class 3 ebike can not have a throttle but every motor vehicle on those streets effectively is throttle controlled so no way can they claim that policy makes sense (it only makes sense if you are being paid $millions by EU companies to promote harmonized speed pedelec policy but all class 3 EU ebikes were compliant to the federal definition as bikes so there was not need for them to define 3-classes. I will not even go into the lunacy of Class 1 and 2 (there is not difference in the real work between a 20mph throttle-assist and pedal-assist drive system. I know some on these forums will claim it was the only way that ebikes got trail access but they just drink the koolaid and really don't understand how that happened.

 

[m@Robertson]

A kite OMG. Why on earth was he flying a kite from the bike lane lol. Was it upwind from a park or something?!?!

Here in Fresno CA we have steady, strong afternoon winds late in the afternoon. Couple it to the heat here (its 104 right now) and you have a blast furnace. I carry a Kestrel anemometer with me oftentimes and on Friday we had steady 10 mph with - not gusts, but ... waves - up to 15. Kite weather I guess.

 

[m@Robertson]

Let me give you an example of brain dead policy. They suggest that class 3 ebike be restricted to use on street and road side bike lanes. A class 3 ebike can not have a throttle but every motor vehicle on those streets effectively is throttle controlled so no way can they claim that policy makes sense

It makes sense if you count in the 28 mph Class 3 speed limit. I think all of us realize that 28 mph is waaaay too much speed to be carrying when intermingling with pedestrians. So... street-only. The decision has nothing to do with the bike and everything to do with the people walking.

Clearly the 3-class system was designed to be conformative with the EU's bike regs, with Class 3 being a best-fit to the EU's km/h speed pedelec. We didn't get the < 4 kw limit because we already had the CPSC definition capping bicycle shaped devices to 749w, so ... again ... Class 3 was a best-fit within existing strictures.

And its working pretty well, but in a very Amwerican way. The rules suck so everyone is ignoring them and making things that do work. The toothpaste is already pretty much out of the tube here. Poke the bear hard enough and they might just wake up. Hence my position that poking that bear is entirely counterproductive. These are nits that do not need picking.

 

[mschwett]

It makes sense if you count in the 28 mph Class 3 speed limit. I think all of us realize that 28 mph is waaaay too much speed to be carrying when intermingling with pedestrians. So... street-only. The decision has nothing to do with the bike and everything to do with the people walking.

i agree with this, i often ride my turbo creo (class 3, but only 250/300w) along a roughly 2 mile dead flat path along the northern waterfront here, and the choices are the road (half of which has a bike lane) or a mixed use path which varies from 10-20 feet wide but is very heavily frequented by joggers, walkers, dogs, kids, and rented-bike riders. with a tailwind (there's always a west-east wind here in the afternoon) 28mph is easily achievable, even without using that much power. absolutely, completely, insanely unsafe. when i'm riding into the wind, i often ride the path at approx 15mph, which takes some work. with the wind, i ride in the street.

of course the bike is class 3 either way, and i honestly have no idea if it's allowed, but it's usually turned off, which adds to the silliness of what some jurisdictions have done. if a regular bike is legal, a turned-off ebike should be legal too. common sense says that the energy involved in a collision at a given speed and mass is the same with the motor on or off, so a speed limit on the path would suffice.

on this left half, i ride in the on-road bike lane both ways.
on the right half, i ride in the mixed use path at approx 15mph westbound, and in the road at approx 25-30mph eastbound.

i believe this one even has a sign which says "faster bike traffic use road-side bike lane" to discourage people from going dangerously fast in the mixed-use-path.

 

[Ken M]

@Ken.M , I would try to email them , it would be interesting to see what response you would get from PFB.

Yes, i did read the CPSC petition, by what date are they supposed to provide an answer ? AND what could be the consequences if they do make that decision against the 28states who adopted the class 3 system ?

I have emailed multiple contacts at PFBs. I even sent them copies of the petition to get their response. Nothing received back so it's crystal clear they are some what under lock-down to discuss anything on the 3-class policy they promoted because they received lobby money to do so. The FACT that they recently presented it at the CPSC EV Webinar as "voluntary" speaks volumes that they know it violates interstate commerce laws and they don't want the CPSC to be aware of it.

The consequences are negligible because any ebike that is 3-class compliant is still compliant but there will be no need for stickers (the stickers just crack me up) or class programming. What everyone needs to understand is that the federal definition was in place for over 10 years before PFBs was paid to push 3-class as "clarification and improved safety" (albeit the volume of ebikes was pretty low for most of those years but there was no issues as PFBs spins it) - a compliant "low speed electric bicycle" was defined to be just another bike such that the current state traffic/usage laws for bikes could just remain the same (that is simple and made perfect sense). What started my frustration is that I had two ebikes (a Polaris Diesel and an Izip Express) that were both federally compliant ebikes legal to ride in Colorado that were made illegal when 3-class legislation was passed in Colorado. I tried to get comments on this from PFBs and they essentially told me I was wrong (I can assure you I am not wrong as the Polaris has throttle assist to 24mph and the Izip does not have an assist cut-off at all so it continues to provide some assist even past 28mph and this ebike was used by the LA Police department).

There are plenty of people on EBR forums that will say no one is enforcing the use laws so it doesn't matter but that is ridiculous logic - the regulations need to be corrected to ever be able to have local enforcement. Then we have those that claim the only reason ebikes are allowed on trails is because PFBs defined Class 1 ebikes. That is one of my favorite false-hoods because it's such transparent koolaid - does anyone really think the assist technology has any impact on trail damage or safety (keep in mind most park trails typically have a 15mph speed limit so even a class 1 ebike assists past the expected limit).

 

[Oberst]

On my way home from work today some jackass was facing directly away from me, trying to fly his freaking kite. Just standing right in the effing middle of the lane with the kite on the ground in front of him while he goofed with the string. Oh and he had earbuds in. I wanted to run him over on general principles.

The issues to be concerned about that need the most improvement - in my opinion which nobody asked for - all have nothing to do with the occasional cyclist that frequents a bike lane. They all have to do with the people and things surrounding the lane, and the cyclists. You want to make a safe lane? Leave the cyclists alone. All of them. Instead, encourage them. All of them. So there will be sufficient numbers in your/our group to make a difference at the next city council meeting etc. Attacking our own no matter how well intentioned is aiming at the wrong target and only helps to continue to hold us back.

By the way this includes taking shots at the CPSC and government agencies who are helping the cause. They don't need ankle-biters and neither does the cycling community.

Would bet earbuds and lack of situational awareness cause more injuries than any class 3 bike ever does!

 

[Ken M]

i think it's an interesting question, since clearly the amount of damage a vehicle can do to a pedestrian or cyclist is proportional to it's mass and speed. (maybe the square of the speed)

i live in san francisco and start uphill with myself and my kid on a class 1 bike all the time, 250w nominal 500w max. i think if someone wants a 1500w two wheeled vehicle, that's awesome, but at 500lb and 28mph i do not want it in the bike lane with my kid, unless there are some new limitations on speeds and behavior in the bike lanes, on mixed use paths, crosswalks, etc, which frankly i'd rather not see.

conceptually there seem to be two ways to address vehicle safety. 1) strictly regulate the operator and the behavior, as with automobiles - licensing, points, violations, maximum speed, a million other rules. 2) limit the vehicles, whether by size, weight, power, speed, etc. in the US on the road we've mostly done number 1. there is no limit on power, acceleration, and frankly only minor limits on weight and other aspects of vehicle design except performance in a crash and emissions.

I just want to try to address the usage points you bring up. The fact is that many bikers (without motor assist) can sustain speeds of 25+ mph on flats for a significant distance. So the speed differential of pedestrians and bikers on multi-use paths has existed for a very long time. 99% of the time is addressed by bikers just riding rationally when riding with pedestrians in proximity (most bikers know that if they hit someone they are just as likely if not more to suffer an injury so they slow down).

I get frustrated when someone assumes that a speed pedelec that can provide some assist up to 28mph will ALWAYS be ridden at that speed even when around pedestrians. That is just total BS thinking as an irresponsible rider can do that on a traditional bike just as well.

With some cargo ebikes approaching 100lbs it's totally possible for the rider and cargo to put the total weight at 500lbs. I fully agree that that much weight going 20mph is a greater risk to pedestrians but again a responsible biker will not be darting around pedestrians on a 500lb total weight cargo ebike unless they want to face a very high liability settlement if they hit someone.

Our federal definition was unique in that it does allow decent power below 20mph for very effective cargo bikes (allowing some assist past 20mph is not going to get a loaded cargo bike with rider effort to go hardly any faster as the definition is for a 170lb rider on a level surface only so not much help for a 500lb loaded cargo ebike (this is the intelligence that Dr. Currie put into the specification - there is a very clear power limit above 20mph to be what can sustain 20mph with a 170lb rider on a level surface). That makes sense....much more sense that the stupid assist cut-offs that originated in Europe (they wanted to have a 28mph speed pedelec to require registration and insurance on so that ebikes would be neutered from getting to many drivers out of cars but they are going to revisit this stupidity in the near future because a 15mph assist cut-off is just going to kill any chances of some longer commute consideration on ebikes.

 

[Ken M]

Would bet earbuds and lack of situational awareness cause more injuries than any class 3 bike ever does!

I fully agree with your statement. I rode my ebike over 6,000 miles one year and every issue I had with a pedestrian (no accidents) was because they were either on the phone or listening to music can couldn't even hear my bell ring to give notice I was approaching. I had two incidents where the pedestrian literally moved to block my path to go by them and then told me that bikes shouldn't even be on that path or sidewalk even though they were legally allowed on the path I was riding on (some buttwipes love to just be buttwipes).

The reason I want the 3-class legislation preempted is because it will provide a foot hold for those wanting registrations and insurance on Class 3 (and eventually all bikes - anyone that doesn't think the insurance industry wouldn't sell their own children to gouge ebike riders must not see the ivory tower buildings they have) and the federal definition of a "low speed electric bicycle" as a bike is best for the long term adoption rate for ebikes. That is far more important than worrying about those claiming they gained trail access only because of class 1 ebikes (I know they believe that but that doesn't make it true).

 

[Ken M]

It makes sense if you count in the 28 mph Class 3 speed limit. I think all of us realize that 28 mph is waaaay too much speed to be carrying when intermingling with pedestrians. So... street-only. The decision has nothing to do with the bike and everything to do with the people walking.

Clearly the 3-class system was designed to be conformative with the EU's bike regs, with Class 3 being a best-fit to the EU's km/h speed pedelec. We didn't get the < 4 kw limit because we already had the CPSC definition capping bicycle shaped devices to 749w, so ... again ... Class 3 was a best-fit within existing strictures.

And its working pretty well, but in a very Amwerican way. The rules suck so everyone is ignoring them and making things that do work. The toothpaste is already pretty much out of the tube here. Poke the bear hard enough and they might just wake up. Hence my position that poking that bear is entirely counterproductive. These are nits that do not need picking.

Why do you assume that just because an ebike can assist to 28mph that a rider is going to zinging thru pedestrians at that speed all the time? That is just nonsensical thinking. Do you realize that a rider on a non-ebike averaged over 33mph for an hour. Do you assume that guy rides thru pedestrians at that speed so we should somehow neuter his physical capability in some way.

The new 1600hp Bugati can do over 300mph and I don't assume that the owners of those cars are going to ride thru dense neighborhoods at that speed taking out children that just happen to cross the street at the wrong time.

99% of bike and ebike riders will always ride responsibly when pedestrians are present because bikers know they are just as like to be injured in an accident. We need people to stop assuming that assist speed is the speed that the bike will always be traveling at...that is irrational and hurts the industry because then pedestrians feel it's true because so few people in this world even use the cognitive section of their brain.

 

[Ken M]

i agree with this, i often ride my turbo creo (class 3, but only 250/300w) along a roughly 2 mile dead flat path along the northern waterfront here, and the choices are the road (half of which has a bike lane) or a mixed use path which varies from 10-20 feet wide but is very heavily frequented by joggers, walkers, dogs, kids, and rented-bike riders. with a tailwind (there's always a west-east wind here in the afternoon) 28mph is easily achievable, even without using that much power. absolutely, completely, insanely unsafe. when i'm riding into the wind, i often ride the path at approx 15mph, which takes some work. with the wind, i ride in the street.

of course the bike is class 3 either way, and i honestly have no idea if it's allowed, but it's usually turned off, which adds to the silliness of what some jurisdictions have done. if a regular bike is legal, a turned-off ebike should be legal too. common sense says that the energy involved in a collision at a given speed and mass is the same with the motor on or off, so a speed limit on the path would suffice.


View attachment 89247

on this left half, i ride in the on-road bike lane both ways.
on the right half, i ride in the mixed use path at approx 15mph westbound, and in the road at approx 25-30mph eastbound.

i believe this one even has a sign which says "faster bike traffic use road-side bike lane" to discourage people from going dangerously fast in the mixed-use-path.

View attachment 89248

In many situations even 20mph is much too fast for a mixed-use path. The assist level of a 28mph speed pedelec doesn't mean these ebikes are doing that speed on a mixed-use path. We riders need to stop implying that because it empowers the pedestrians to echo that claim. 99% of bike riders ride responsibly on mixed use paths...those that don't will either end up with a liability problem in court or being taken out by a pedestrian with a big stick.

 

[mschwett]

In many situations even 20mph is much too fast for a mixed-use path. The assist level of a 28mph speed pedelec doesn't mean these ebikes are doing that speed on a mixed-use path. We riders need to stop implying that because it empowers the pedestrians to echo that claim. 99% of bike riders ride responsibly on mixed use paths...those that don't will either end up with a liability problem in court or being taken out by a pedestrian with a big stick.

yes, i agree, and know well first-hand how incredibly rarely (never?) i’ve used my class 3 road bike to go 28mph on level ground. of course i ride far faster than that downhill in the road, which can be perfectly safe in the right circumstances.

specifically posted (and enforced) speed limits on various types of bike lanes and paths, paired with a reasonable definition of what a “bike” is seem a fairly easy solution which would address the 1% (including roadies who ride 30 under their own power on paths). the bottom line to me is that a bike lane is distinct in degree of separation and scale from a vehicular lane, and there should be a reasonable range of vehicles permitted. my urban cycling experience would exclude multiple kilowatt, heavy, throttle operated vehicles from our congested bike lanes, but i realize that’s a point of debate. but clearly the line needs to be drawn somewhere, or speed limits in bike lanes need to be much more strictly enforced.

 

[m@Robertson]

Why do you assume that just because an ebike can assist to 28mph that a rider is going to zinging thru pedestrians at that speed all the time? That is just nonsensical thinking.

I never said anything like that. My post is still there so read it again? Or not. This tactic is par for the course with you it seems. You put up a straw man and then use that false premise to pound out more paragraphs. I should have learned from the last time I made the mistake of treating this as a serious discussion. This is just a never-ending word factory. You're worse than I am and thats saying something.

 

[Ken M]

I never said anything like that. My post is still there so read it again? Or not. This tactic is par for the course with you it seems. You put up a straw man and then use that false premise to pound out more paragraphs. I should have learned from the last time I made the mistake of treating this as a serious discussion. This is just a never-ending word factory. You're worse than I am and thats saying something.

I understand .... but when you write "I think all of us realize that 28 mph is waaaay too much speed to be carrying when intermingling with pedestrians. So... street-only." It sure seems to me to imply that a speed pedelec is only pedestrian-safe if restricted to the street only which somewhat implies it's commonly at 28mph regardless of situation or path. 20mph is too fast when intermingling with pedestrians so should we reduce Class 1 and 2 to say the EU mamby-pamby assist limit of 15mph? I believe a respectful rider can ride a speed pedelec on a mixed use path just as safety as a Class 1 or 2 ebike but that is ignored by those justifying the need for two speed classes (the speed classes were EU harmonization elements ... nothing to do with safe riding principles).

Note: I'm not advocating that 5000W 70mph emopeds/cycles be allowed on sidewalks but I think all CPSC compliant ebikes should be.

My only goal in all my input on these forums is bringing attention to the federal / CPSC definition of a "Low Speed Electric Bicycle" and what seems to have been the original intent back in 2001 when being promoted into law that it be just another definition of a bike type (like recumbent, trike, gravel, etc.) and traffic / use regulated as a bike. They were trying to remove the label that an LSEB is a motorized vehicle but that mindset still exists 20 years later with some lawmakers and certainly trail managers who continue to claim they are motorized vehicles. I understand they have a motor .... but one with the power of the average home toaster.

The federal definition crystal clearly (if you understand it was written by a PhD Electrical Engineer) sets a power limit at and above 20mph per the constraints of 170lb rider on level surface that by simple physics is going to keep compliant LSEBs in the typical distribution for bikes speeds. Anyone can run the simulations to see that this is an accurate statement.

 

[Ken M]

yes, i agree, and know well first-hand how incredibly rarely (never?) i’ve used my class 3 road bike to go 28mph on level ground. of course i ride far faster than that downhill in the road, which can be perfectly safe in the right circumstances.

specifically posted (and enforced) speed limits on various types of bike lanes and paths, paired with a reasonable definition of what a “bike” is seem a fairly easy solution which would address the 1% (including roadies who ride 30 under their own power on paths). the bottom line to me is that a bike lane is distinct in degree of separation and scale from a vehicular lane, and there should be a reasonable range of vehicles permitted. my urban cycling experience would exclude multiple kilowatt, heavy, throttle operated vehicles from our congested bike lanes, but i realize that’s a point of debate. but clearly the line needs to be drawn somewhere, or speed limits in bike lanes need to be much more strictly enforced.

Let me ask you this...What is a more reasonable definition of a compliant ebike to be considered a bike for traffic / use....the federal definition or the 3-class parsing system being pushed by People for Bikes?

We should all keep in mind that by law the CPSC controls what is legal for 1st sale so I have no clue how the federal definition and 3-class can simultaneously exist because many buyers are buying ebikes that the CPSC considers compliant that are actually illegal to ride in the state those buyers will be ridding them (and they have no clue they will be ridding an illegal ebike that could result in big liability issues if they do have an unlucky accident)).

 

[antboy]

I never said anything like that. My post is still there so read it again? Or not. This tactic is par for the course with you it seems. You put up a straw man and then use that false premise to pound out more paragraphs. I should have learned from the last time I made the mistake of treating this as a serious discussion. This is just a never-ending word factory. You're worse than I am and thats saying something.

I'd agree with Ken's assessment of your comment. It's not a straw man in any way.

It makes sense if you count in the 28 mph Class 3 speed limit. I think all of us realize that 28 mph is waaaay too much speed to be carrying when intermingling with pedestrians. So... street-only. The decision has nothing to do with the bike and everything to do with the people walking.

The implication is that a Class 3 bike will be ridden at that speed, even on crowded MUPs. There's not a lot of other ways to interpret that. The decision has EVERYTHING to do with the bike.

As a Canadian, I only chime in because PfB's marketing has bled into the minds of local legislators here, to the point where Class 3 is specifically not even available for sale. Canadian legislators often can't make up their minds whether they're European or American, and we get the worst of both worlds, to the point where...

The Emmo Zone GTS is considered an ebike, perfectly legal to ride on MUPs.

And the Vado SL 5.0 isn't...

I think this just highlights the ignorance of legislators.