So what’s your end game here? I know a lot of people in bike advocacy, and the 3 class system is directly responsible for the rapid acceptance of ebikes in the traditional bike advocacy world. It sets limits on powered bikes that people are comfortable with. You seem proud of trying to throw it out, but I’m unclear why anyone who likes ebikes would think that’s a good thing. Undo that and it would undo a lot of advocacy.
Logically the commercial arrival of affordable Lithium Ion Batteries is behind the rapid acceptance of ebikes (It's nice that the marketing of 3-class claims credit but guess what? ... it simply isn't true ... not even remotely). Keep in mind there are 24 states that have not adopted 3-class and I'm sure the sales growth in those states is just a good as in the 3-class states.
I’m not talking about consumer acceptance of ebikes, I said advocacy/institutional acceptance of ebikes. You know, the people who have been in the trenches fighting for bike access since well before ebikes existed. People whose work we are trying to piggyback onto.
It is confusing and complex. I posted the full petition filed with the CPSC so anyone interested can read all the "citation" claims made.@Ken M I have to agree here, I don't know what you're trying to accomplish.
I'm sure anyone here on EBR is all for whatever is good for ebikes, but I think many people are confused.
Could you paraphrase your analyses and proposal in one paragraph (if possible) without jargons or anything?
Because if you're actually trying to convince people, get a petition, whatever you do, it is important that your writing is short, simple and something that could be understood by everyone.
I don't know if I would, or how many people would want to be reviewing scholarly articles with 25+ citations like one that you posted.
Can u post the link to file the petiton so, that others can do it as well ? I will look it up online if I find it , i'll post it.
Tim, The petition was filed as written in my initial post. I posted a couple surveys a while back and I think you did respond to one but overall there was not much feedback so I just went ahead with executing my plan to petition for preemption. Simply stated that means I'm asking the CPSC to end the standing of the 3-class regulation in all 26 states that have adopted it because primarily it violate their interstate commerce intent of their regulatory powers. Please look up how important explicit / expressed preemption is and note that it was part of the HR727 adoption of the low speed electric bicycle definition.@Ken M I have to agree here, I don't know what you're trying to accomplish.
I'm sure anyone here on EBR is all for whatever is good for ebikes, but I think many people are confused.
Could you paraphrase your analyses and proposal in one paragraph (if possible) without jargons or anything?
Because if you're actually trying to convince people, get a petition, whatever you do, it is important that your writing is short, simple and something that could be understood by everyone.
I don't know if I would, or how many people would want to be reviewing scholarly articles with 25+ citations like one that you posted.
Actually numbers don't matter in their petition process - I just hope people feel I did the right thing if it succeeds (I wasn't going to file the petition unless I found legal precedent but I felt I did as part of the notes on a bike lighting decision made back in 1978 - cool it was same industry). Me filling is basically the same power as $100 billion corporation filing.
??Ty, i get all the legal terms you metioned and had read the posts.
Why can't we just have the "Law of Common sense"
In retrospect what they do now with the division of ebike classes , it may be in order to set up a platform in order to bring insurance for class 3 ( no americans will buy a class 3 ebike If that will occur !). Also if we look at some recent very light class 1 ebikes(25-35lb) , one fit rider can easily outpower the motor above 20mph, turning his ebike into a class 3 human powered.
Are u saying that whether 1 individual or
5 file that petition , it could have the same outcome ? They may loose it , if it's only 1 .
ps: that's amazing that Mr. Currie is around !! I wonder what ebike does he ride ?
....forgot to mention that I do hope to at least talk to Dr. Currie soon. I've been exchanging emails with his old partner's son and he's helping me in my research to confirm the original intend of the federal definition. I just have to know and then no one else's opinion will have much merit in my opinion because he was behind wrestling away ebikes from the NHTSA so all of us riders own him our gratitude.Ty, i get all the legal terms you metioned and had read the posts.
Why can't we just have the "Law of Common sense"
In retrospect what they do now with the division of ebike classes , it may be in order to set up a platform in order to bring insurance for class 3 ( no americans will buy a class 3 ebike If that will occur !). Also if we look at some recent very light class 1 ebikes(25-35lb) , one fit rider can easily outpower the motor above 20mph, turning his ebike into a class 3 human powered.
Are u saying that whether 1 individual or
5 file that petition , it could have the same outcome ? They may loose it , if it's only 1 .
ps: that's amazing that Mr. Currie is around !! I wonder what ebike does he ride ?
Except nowhere I ride my class 1 is governed by that order. Its a mixmash of local, county and state parks and trails. I've talked to land managers in the past and have many friends involved with advocacy, and the class 1 definition is what is allowed. They explicitly do not want faster bike or throttles on any of their trails (which makes absolute sense). If the definition changes so that they would have to allow anything faster or anything with a throttle, I can say with relative certainty they would simply ban ebikes altogether.
I'm not banging my head against the wall. The petition is filed and the CPSC general counsel will make a decision - it up to the lawyers to decide. I'm fine either way as if they decide that 3 class is acceptable then they will have to change the bike regulation to accommodate the classes. I do not think they will do that because they own interstate commerce / 1st sale. States have "use" which I don't think includes the right to redefine low speed electric bicycles into 3 (or 4 classes).
Finally! This was long overdue, I really hope the 3-Class System is destroyed forever. I always felt the potential motivation when People For Bikes introduced Class 3, was to eventually extract insurance/registration on E-Bikes. The insurance lobby money would be HUGE amounts. The insurance industry has been drooling to get their teeth into bike insurance for a century. Note - This is already a done deal in Europe, (EU "Speed Pedelec" = harmonized as Class 3 in US by P4B). I don't know about anyone else, but I despise insurance companies aka - Dispute/Delay/Deny. I'm sorry People For Insurance, but no one wants insurance mandatory on E-Bikes! Also, in April, 2019 the Bike Product Suppliers Association joined with People For Bikes. It seems strange to me that an organisation called "People For Bikes" (pretty Orwellian) admitted that they took lobby money from Bosch? Is P4B promoting the interests of people or are you promoting industry? This is a blatant example of regulatory capture done sloppy. On a side note - Bosch is the #1 auto parts supplier in the world and made 85.9 billion on car parts last year. So the true strategy and motivation of of auto suppliers is to control the pace of E-Bike adoption. Make them just slow enough (Class 1/2) that you're forced to get into your car and wear out your fancy Bosch brake pads, because some cyclist on a slow E-Bike is in the middle of the damn road! Class 3 option is faster but will be expensive (insurance - eventually in class 3). Bosch is reducing the competitive edge of E-Bikes for corporate profit. They don't want E-Bikes to compete too much with their existing revenue stream. Can you blame them? How many chain rings, derailleurs and motors would you need to sell to replace that 85.9 billion? However, do we really want the #1 Auto Parts supplier in the world influencing our E-Bike policies? The ONLY people that seem to like the Class System are the big players, who coincidentally seem to also sponsor People For Bikes. Car and motorcycle parts make up 90% of Bosch's revenue, as well Brose only receives 0.5% of its profit from E-bike motors. BOTTOM LINE - Bicycle parts DON'T bring in the margins, hate to say it - but it seems that's the real truth. They are controlling the pace of E-Bike adoption and steering the revenue via regulatory capture - it's really not rocket science. There are also other reasons too, industry set the standard in the EU at 250w motors to gain market share over the Chinese hubs (to reduce competition in the EU market at the time). Anyone in the industry knows that a 250w rear hub is NOT competitive with the mid drives. This is how the world of big business operates. Why is ANYONE defending People For Bikes? Why would anyone have loyalty to them? If you want to buy insurance and registration, then stick with them.
This, a thousand times. People complaining about the 3 class system and the proponent of somehow using the CPSC to throw it out in states that have adopted it have been extremely vague about what the actual benefit would be to e-bikers if that were to happen.
Maybe someone should have to state what the actual benefit to e-bikers was with the adoption of 3-class. Class 1 & 2 are essentially the same (the argument that the power is delivered differently is not tangible when you consider that most cadence pedelecs are just on/off switches for assist) and class 3 is still in the traditional speed distribution for human powered bikes. Are there reports of problems in the states that have not adopted the 3-class legislation? Are multi-mode ebikes blurring the lines on how enforcement of the class system will ever be possible?
