Statement Regarding Potential CPSC Ebike Law Preemption of 3-class Legislation

[Ken M]

CpSC is the Federal Consumer Product Safety Commission. In a nutshell to summarize, the argument is Federal government sets safety standards for what bikes including what e bikes can be sold in the US. Preemption means states cannot act on matters where the Federal government has acted. Further that we cannot have each set a different standard.

Thank you...good summary. I believe on the vast majority of products the states just accept the CPSC standard (1st sale) and focus on "use" policy when appropriate.

 

[Mr. Coffee]

CpSC is the Federal Consumer Product Safety Commission. In a nutshell to summarize, the argument is Federal government sets safety standards for what bikes including what e bikes can be sold in the US. Preemption means states cannot act on matters where the Federal government has acted. Further that we cannot have each set a different standard.

Not to get into the weeds, but the Consumer Products Safety Improvement Act of 2008 reiterates that the CPSC does not have the power to preempt state law beyond what Congress has authorized in earlier statutes.

A bunch of assumptions about a thorny and confusing part of US Federal Law are being made here. I lack the expertise to evaluate those assumptions and would feel better if an expert in this topic had weighed in with a well-researched legal opinion.

Similarly, how such rule changes would affect the street-legal status of e-bikes and their access to bicycle infra, multi-use paths, and bicycle trails is wildly unclear to me and I'd love to hear from people actually involved in those issues about what they'd think about it.

The author and originator of this thread has obviously put considerable time and effort into this. I do honor him for that. My criticism is not intended to besmirch that. What I think might improve his proposal is soliciting input from relevant domain experts.

 

[Ken M]

Not to get into the weeds, but the Consumer Products Safety Improvement Act of 2008 reiterates that the CPSC does not have the power to preempt state law beyond what Congress has authorized in earlier statutes.

A bunch of assumptions about a thorny and confusing part of US Federal Law are being made here. I lack the expertise to evaluate those assumptions and would feel better if an expert in this topic had weighed in with a well-researched legal opinion.

Similarly, how such rule changes would affect the street-legal status of e-bikes and their access to bicycle infra, multi-use paths, and bicycle trails is wildly unclear to me and I'd love to hear from people actually involved in those issues about what they'd think about it.

The author and originator of this thread has obviously put considerable time and effort into this. I do honor him for that. My criticism is not intended to besmirch that. What I think might improve his proposal is soliciting input from relevant domain experts.

Thanks of the respectful comment about the effort. I did try to get feedback from others but I think this is a fairly complex boring subject for most. My original interest was because my ebike went from legal use status to illegal use status after Colorado adopted 3-class and that made no sense to me. Some deny this even happened via claims that 3-class is consistent with the federal definition.

One thing you may want to research is how significant an explicit / expressed preemptive clause is in a federal CPSC law (HR727 has that so congress did authorize this power on the definition of "low speed electric bicycles)." I'm a 60 year old engineer with no legal background but I felt my research supported the petition adequately and I felt I found a precedence statement from the CPSC in the example provided in the petition. The good news is that if the 3-class is preempted then the legal default would probably be the federal definition as a bike for state "use" regulations which people will find a lot less confusing.

 

[elliot friedman]

I hear what you are saying and it is far from an exact correlation. My point is that with cars, you regulate the behavior rather than the capability.

I agree, I can pedal a class 3 ebike as slow as any class 1 or 2.

 

[jabberwocky]

There is a TedTalk video on the internet where data is presented showing that ebikes are the most efficient way to move a person from A-to-B ... even more efficient that a fully loaded passenger train or walking because of calories consumed. While I respect what land managers have to deal with, the benefit to the world that ebikes can provide makes their bias against throttles a total non-starter for me - I rather them ban all bikes from their trails than allow them to have a negative impact on a great urban mobility solution that is cleaner, healthier, & more efficient than anything else. I am not on a mission to hurt ebike potential or adoption...the intent is totally the opposite so if harmonization was even a factor in PFBs pushing the 3-Class legislation then the intent was not as stated. Europe how has the standard assist speed limited to 15.5mph (while you can still drive the autobahn at 200mph+), a return to the federal definition would prevent any effort of re-harmonizing efforts via added classes (PFBs has suggested this in one video for eMTBs).

Wow. So you're fine with throwing trail access for all bikes (not just ebikes!) under the bus to change things in a way that you still haven't explained is actually better than what we have now.

For someone who claims to not be on a mission to hurt ebike adoption, you sure are dismissive of the potential damage of what you're trying to do.

Honestly, if you want to help, get off the damn computer, look up your local bike advocacy org and fricking get involved. You have a lot of energy that is currently IMO being directed in an extremely unhelpful way.

 

[PM Cycles]

As far as I'm aware, no state has even discussed (much less considered legally requiring) insurance on any ebike, nor is it a plank at any advocacy org, including PFB. The whole "the 3 class system is a back door conspiracy to require insurance" comes across as entirely tinfoil-hat to me, at least in the US.

Seeing industry support of advocacy orgs as some sort of conspiracy just says you have no experience in bicycle advocacy. Its a pretty normal thing and long predates ebikes. Expanding access expands the market, whether its increased legal access for ebikes, more trail for mountain bikes, better commuting infrastructure, etc. The more people riding, the more potential customers for your product (and its good PR as well). The idea that Bosch is trying to cripple the ebike market to help their car business is just... ludicrous? If nothing else, Bosch has a ton of competition in the motor market, so its not like people don't have a choice if they don't like what Bosch is pushing.

First of all, let me clarify that my ONLY criticism of P4B is the 3-Class Legislation. I'm for all the other work they do on bikes and E-Bike advocacy, and I would be more than happy to donate money to them for these efforts. I might have come off as a little harsh on P4B and just wanted to apologize for that (im pretty emotional..lol). I'm genuinely worried that the US will go down the same path as the EU and put MANDATORY insurance on Class 3. For example, let's assume in the next 10 years - 35 Million Americans (10% of the population) want to use an E-Bike for commuting. The policy for an E-Bike insurance would probably be somewhere around $500 / year? ( $40 / month). That would generate a 17.5 billion yearly revenue stream for insurance - pretty lucrative if you ask me. Note: I'm not against insurance per say, my issue is with it being mandatory on Low Speed E-Bikes (including Class 3). And the path PFB was on, seems heavily correlated with the European path. Why are we matching EU laws? Look at the mess the E-Bike laws are in the EU. And besides, the EU lowered the speed to 15mph to push more cyclists into the high speed pedelec class that requires insurance and registration. So the PFB Class 1&2 laws are not even harmonized with Europe anymore. If insurance wants they should lobby for insurance on HIGHER Speed Electric Bikes (increase power limit on HSEB), but most likely that would be under the DOT umbrella with mirrors, brake lights, signals, insurance etc.(and I would be fine with that). The original law makers worked hard to get E-Bikes out from under DOT, and to match the performance of a LSEB to a regular bike. The law was written so that an LSEB=Bicycle, as to avoid denial of access like the DOI recently ruled. It reduces power at 20mph, and allows you to maintain that speed, and ADD additional human power (if you choose), which unless you are an olympic cyclist, is about 24-28mph (about the top speed of regular bike)!!!! Faster down a hill of course, but do we slow down regular bikes when they go down a hill? Why is it justified to limit speed on an E-Bike and not a regular bike - the feds say a Bike=E-Bike - when did it change?(stricter definition goes against CPSC law). I have seen people go down steep hills on slim road bike tires doing 55mph (scary). Maybe we should then ban ALL bikes from going faster than 28mph? Does anyone see a conflict here? Conclusion - THAT'S WHY POWER LIMITS ARE BETTER THAN SPEED LIMITS.

The 3-Class system WAS INTENTIONALLY matched to EU laws with help / advice from industry.

On Monday the lead at PFB 3 class legislation left a $75,000 @ PFB job (if anyone wants to apply) after trying to get New York laws to match the 3-Class system that included a Class 3 throttle at 25mph (not a 28mph non throttle pedelec like PFB Class 3). I'm speculating that the lawyers in New York told the PFB rep that the P4B class table doesn't match the federal definition. Just seems a weird time to quit after working so hard to pass laws into all those other states. New York decided to go their own way and limit Class 3 to 25mph throttle compared to 28mph pedelec (PFB). As well, MN/NV/KS has banned Class 3 E-Bikes in the state, and some require additional E-Brakes on all classes? So MN/NV/KS and New York don't match the P4B Class table either (even though they "adopted" the 3 Class). Also, at least 22 states don't have any state E-Bike laws on the books and use the CPSC standard. Some states even have less stringent laws than the CPSC and allow 1000w E-Bikes. So technically the US now has 5 different standards in the country. This is where PFB made mistakes, INDUSTRY DOESN'T want 5 different standards in one country! Which the rep from P4B knows, and why they got so frustrated with New York. Here PFB states that since 2002 that the feds control the first sale. If P4B knew the feds control first sale, then why did they require state laws for speedometer (class 3), stickers/labeling and speed governing? Again, it leads me to believe there is a secondary agenda - they are contradicting themselves left, right and centre. They must have known this is not consistent with the federal law. State laws control use - that's not use. Then later PFB states because an E-Bike=Bike and has no speed limit (only power limit) - they thought it was a good idea to cap the speed to the EU standard. I'm not sure about that logic, I don't think any Americans want to be like the French!

There is a company that has developed an E-Bike that switches between all the 4 modes (includes offroad) on the controller and some rumors about a digital sticker that would switch with the modes. You can already buy Class Stickers on EBay. So again, what's the point of these 3-Classes if you can just arbitrarily switch between them and become at least visually "compliant"?

I don't think it's too conspiratorial to question why so many car and car part manufacturers are funding E-Bike legislation around the world. The information I posted WAS from an industry insider, who has been in the industry 30+ years designing bikes. I asked him, what is the motive behind all this? Why are they limiting the potential of E-Bikes? I was genuinely concerned - and very naive I guess, when he explained about the margins, and the profitability it made perfect sense to me as I have a background in business. The car industry does to some extent feel threatened by this technology. They are trying to steer it into their favor. Why is this so surprising to everyone? We would all probably do the same if we had a 85.9 Billion dollar revenue stream! Here are the companies funding PFB (see attached) they jointly donated 1 million to PFB. Many of the donors are heavily tied to the car/motorcycle industry as well. Does this E-Bike look like something that could compete with cars? This is a last mile solution that COMPLIMENTS cars, doesn't replace them as a form of transport. The insider in the industry told me this is called "defensive development". In the article, GM blames COVID, however - E-Bike sales spiked during Covid!?

Please don't attack the messenger, I really don't like writing these posts. It's difficult and hard to understand what exactly is the truth, and I could be wrong on many points. So, this is merely my opinion, take it for what it is. My intention is for expanding E-Bike use. It's my opinion that the 3 Class laws merely confuse consumers (as seen on here), creates too many standards for manufacturing and leaves the door wide open eventually introducing mandatory insurance and registration on Class 3. In terms of the other work PFB does, I consider them a great organisation (except the 3-Class). Thanks.

 

[Mr. Coffee]

... The policy for an E-Bike insurance would probably be somewhere around $500 / year? ( $40 / month).

Exactly where did you get that number? I own a large SUV and drive a lot of miles and my liability insurance on that SUV is about $500/year.

Liability insurance for motorcycles is usually less than half that. I'd think that a lighter weight speed-restricted e-bike would cost less to insure than a motorcycle.

 

[Ken M]

Wow. So you're fine with throwing trail access for all bikes (not just ebikes!) under the bus to change things in a way that you still haven't explained is actually better than what we have now.

For someone who claims to not be on a mission to hurt ebike adoption, you sure are dismissive of the potential damage of what you're trying to do.

Honestly, if you want to help, get off the damn computer, look up your local bike advocacy org and fricking get involved. You have a lot of energy that is currently IMO being directed in an extremely unhelpful way.

Not exactly what I said but some will interpret it that way. My position is do we want trail manager's views driving the regulations that impact the adoption for urban mobility? I think not.

I did reach out to PFBs well before going this direction. They told me my PIM Archer that has throttle-assist past 20mph is class 3. When I questioned this I just got the response that they were the experts. They were as receptive and open-minded as you are to the suggestion that maybe 3-class does cross a legislative no-no line.

I could spend more time presenting simulations on how the top assist speeds of the federal definition using power as a limit instead of assist cut-offs results in ebike top speeds in the 24-30mph range (ie withing traditional bike 3-sigma speed ranges) but no one really wants to see objective facts that don't align with their opinion. The age of the internet enables inaccurate opinions to propagate. Please keep in mind, trail access was never mentioned as goal of the 3-class legislation - always claimed was improved "clarity and safety."

 

[PM Cycles]

Exactly where did you get that number? I own a large SUV and drive a lot of miles and my liability insurance on that SUV is about $500/year.

Liability insurance for motorcycles is usually less than half that. I'd think that a lighter weight speed-restricted e-bike would cost less to insure than a motorcycle.

It was just a "guesstimation" and it was 10 years from now, so adjust for inflation (2.9%+) which seems to be on the rise. I pay $88 / month for liability on my car. Let's just agree that the insurance profit would be in the billions. If anyone wants to investigate what it currently costs, People For Bikes have a nice page on insurance companies that offer E-Bike insurance.

 

[jabberwocky]

I don't think it's too conspiratorial to question why so many car and car part manufacturers are funding E-Bike legislation around the world. The information I posted WAS from an industry insider, who has been in the industry 30+ years designing bikes. I asked him, what is the motive behind all this? Why are they limiting the potential of E-Bikes? I was genuinely concerned - and very naive I guess, when he explained about the margins, and the profitability it made perfect sense to me as I have a background in business. The car industry does to some extent feel threatened by this technology. They are trying to steer it into their favor. Why is this so surprising to everyone? We would all probably do the same if we had a 85.9 Billion dollar revenue stream! Here are the companies funding PFB (see attached) they jointly donated 1 million to PFB. Many of the donors are heavily tied to the car/motorcycle industry as well. Does this E-Bike look like something that could compete with cars? This is a last mile solution that COMPLIMENTS cars, doesn't replace them as a form of transport. The insider in the industry told me this is called "defensive development". In the article, GM blames COVID, however - E-Bike sales spiked during Covid!?

"Car and car part manufacturers"? You mean companies like Brose and Bosch who... make ebike parts? How weird, that companies that make parts for ebikes would support an organization that advocates on behalf of ebikes. Next you'll tell me that companies that make mountainbikes support IMBA. Must be a conspiracy!

As for why companies like Bosch got into the ebike game, it makes a lot of economic sense? They have some expertise in electric drive systems and its easy to see that its a field with a huge growth potential, so why not hedge your bets and diversify. Bosch in particular makes a ton of s*it. None of my ebikes have Bosch motors but I have several power tools and a dishwasher with their name on it. Maybe their dishwasher division is trying to cripple ebikes because people out riding bikes eat out a lot and don't need to wash dishes?

I'm still really unclear how PFBs model legistlation is supposed to be a backdoor to killing ebikes popularity. From where I sit, ebikes have been exploding in popularity over the last year and access has been rapidly expanding, so if its adoption was supposed to kill ebikes it seems to have been a miserable failure. I see a lot of anger towards it in this thread with very little explanation for the root of that anger. Is it just the usual "I resent all rules and think I should be able to do what I want" or is there something targeted about the 3 class system that ruffles your jimmies?

 

[PM Cycles]

"Car and car part manufacturers"? You mean companies like Brose and Bosch who... make ebike parts? How weird, that companies that make parts for ebikes would support an organization that advocates on behalf of ebikes. Next you'll tell me that companies that make mountainbikes support IMBA. Must be a conspiracy!

As for why companies like Bosch got into the ebike game, it makes a lot of economic sense? They have some expertise in electric drive systems and its easy to see that its a field with a huge growth potential, so why not hedge your bets and diversify. Bosch in particular makes a ton of s*it. None of my ebikes have Bosch motors but I have several power tools and a dishwasher with their name on it. Maybe their dishwasher division is trying to cripple ebikes because people out riding bikes eat out a lot and don't need to wash dishes?

I'm still really unclear how PFBs model legistlation is supposed to be a backdoor to killing ebikes popularity. From where I sit, ebikes have been exploding in popularity over the last year and access has been rapidly expanding, so if its adoption was supposed to kill ebikes it seems to have been a miserable failure. I see a lot of anger towards it in this thread with very little explanation for the root of that anger. Is it just the usual "I resent all rules and think I should be able to do what I want" or is there something targeted about the 3 class system that ruffles your jimmies?

As posted earlier, you conveniently failed to mention the difference in profit margins between car parts and E-Bike parts. Which was the premise of the whole argument. Not once did I claim to be surprised they are involved in the bike industry. But whatever, I guess it's only me that could be wrong about something right? My issue is with manipulating regulation. This is standard in all industries (finance/healthcare/agriculture/law etc.) I'm telling you right now, the industry is the one that doesn't like this. Not how they messed up and have 5 different laws now. It's also very naive to think the 3 Class is popular with ALL consumers. E-Bikes exploded because of COVID and people couldn't go to gyms and had more spare time to exercise. It's a little conspiratorial to think the high adoption rate was because of the PFB legislation - It happened in other countries without PFB. Neither of us are lawyers, so let's see what the CPSC decides. If the states broke the law, then it will need to be addressed. One last question for you, have you taken money from PFB for E-Bike advocacy? I'm happy you are an E-Bike advocate - just saying it can create a bias / conflict of interest in your reasoning. You seem pretty emotionally attached to this thread.....this will be my last comment, I have said my piece.

 

[jabberwocky]

As posted earlier, you conveniently failed to mention the difference in profit margins between car parts and E-Bike parts. Which was the premise of the whole argument. Not once did I claim to be surprised they are involved in the bike industry. But whatever, I guess it's only me that could be wrong about something right? My issue is with manipulating regulation. This is standard in all industries (finance/healthcare/agriculture/law etc.) I'm telling you right now, the industry is the one that doesn't like this. Not how they messed up and have 5 different laws now. It's also very naive to think the 3 Class is popular with ALL consumers. E-Bikes exploded because of COVID and people couldn't go to gyms and had more spare time to exercise. It's a little conspiratorial to think the high adoption rate was because of the PFB legislation - It happened in other countries without PFB. Neither of us are lawyers, so let's see what the CPSC decides. If the states broke the law, then it will need to be addressed. One last question for you, have you taken money from PFB for E-Bike advocacy? I'm happy you are an E-Bike advocate - just saying it can create a bias / conflict of interest in your reasoning. You seem pretty emotionally attached to this thread.....this will be my last comment, I have said my piece.

I do no advocacy at all at the moment, and my history in advocacy was entirely with non-electric mountainbike stuff. I still have a lot of friends who volunteer with various orgs (mostly the local IMBA affiliate, but some who work with WABA). I actually know almost nobody who specifically does ebike stuff, though the WABA people have been proponents of ebikes for a really long time since they approach it mainly from a commuting/general transportation perspective.

Sorry you feel like I'm saying you're wrong, but you're making vague claims and not backing them up. Explain how PFBs model legislation is a gift to the car industry or was somehow created to limit ebike uptake at the behest of companies like Bosch.

 

[Asher]

World class sprinters can come close to 28mph so should we worry about their top speed potential if on a trail?

"You can't set low speed limits because what if Usain Bolt sprints at 30 mph down your street?!?" As Jabberwocky suggested, just because something is possible, it doesn't mean it is likely. But when you strap a motor to something, that changes the likelihood, or prevalence, a lot.

It's funny, that of all the criticisms one could make of the ebike industry, for conspiratorial behavior, only the false ones are being dredged up. Here's a couple that are actually true: near monopoly of Bosch in Europe in terms of market share, proprietary battery standards that devalue used bikes and inflate prices of replacements. A subsidy bill to boost adoption (E-BIKE act) when bikes are already sold out, so the subsidy is pointless for the near term.

 

[Ken M]

I do no advocacy at all at the moment, and my history in advocacy was entirely with non-electric mountainbike stuff. I still have a lot of friends who volunteer with various orgs (mostly the local IMBA affiliate, but some who work with WABA). I actually know almost nobody who specifically does ebike stuff, though the WABA people have been proponents of ebikes for a really long time since they approach it mainly from a commuting/general transportation perspective.

Sorry you feel like I'm saying you're wrong, but you're making vague claims and not backing them up. Explain how PFBs model legislation is a gift to the car industry or was somehow created to limit ebike uptake at the behest of companies like Bosch.

I do want to input a technical point. I do believe it's plausible that Bosch understood that a 250W continuous rating in the EU would impact the potential of the low cost DD hubs from China to allow the mid-drive configuration they were developing to get some market traction. Bosch and Brose do want the EV market to grow but it's plausible that they don't want the adoption of ebikes to quickly displace too much car usage (in other words "defensive development" is not new to industry). The fact that Europe does have insurance requirements for speed pedelecs is an obvious reason to be concerned that insurance requirements could use the class 3 as a foothold (I'm sure anyone that knows that industry knows they are a powerful lobby industry that would sacrifice children for more mandatory insurance laws on anything).

Someone has posted a survey of 718 bikers that were asked if they thought a single definition of an ebike to be considered a bike for all "use" would be best. 84% said yes. Not a huge sample but large enough to have statistical confidence in the majority view.

I encourage everyone to watch this video and pay close attention to the comments about the 2002 federal definition essentially defining an ebike as a bike and then the comments hoping the same thing for the 3-class legislation. If PFBs has that goal for 3-class legislation, why not advocate that all federally compliant ebikes be "use" treated as just bikes? Congressional notes PROVE that was the intent of the original definition...oh but I'm guessing NO ONE has read those notes because that requires interest in some effort (easier to drink the 3-class koolaid). In the same video the harmonizing with Europe is mention as being a driver for the 28mph assist limit on Class 3. Completely ignored is that the federal definition has a power limit that results in pretty much the same top speed with motor and human combined but without a cease of assist. I have never heard rider/consumer say they like the 20/28mph cease of assists. Also pay close attention to the admission that a few people in a room essentially came up with the 3-class system ... do we really want to support the "few people in the room" process? I have no clue (other than harmonization) what the motivation to parse the federal definition into 3 classes was - most states were already "use" treating compliant ebikes as just a bike (many still do and sales in those states doing just as well). Is the claim the classes improved access for ebikes even remotely true? All I want is for everyone to spend the time to decide what the truth is (don't just drink the koolaid...educate yourself).

 

[Asher]

I do want to input a technical point. I do believe it's plausible that Bosch understood that a 250W continuous rating in the EU would impact the potential of the low cost DD hubs from China to allow the mid-drive configuration they were developing to get some market traction. Bosch and Brose do want the EV market to grow but it's plausible that they don't want the adoption of ebikes to quickly displace too much car usage (in other words "defensive development" is not new to industry). The fact that Europe does have insurance requirements for speed pedelecs is an obvious reason to be concerned that insurance requirements could use the class 3 as a foothold (I'm sure anyone that knows that industry knows they are a powerful lobby industry that would sacrifice children for more mandatory insurance laws on anything).

Someone has posted a survey of 718 bikers that were asked if they thought a single definition of an ebike to be considered a bike for all "use" would be best. 84% said yes. Not a huge sample but large enough to have statistical confidence in the majority view.

Insurance is required primarily because insurance was already required for mopeds going the same speed. I'm not saying it's a good idea per se, to require insurance on s pedelecs, but it's not some requirement out of nowhere. Maybe the moped companies wanted it that way, but it's not out of character.

As for a survey, of course people want a simpler law, but they haven't thought thru issues like access to parks, which you continue to ignore or dismiss.

 

[Ken M]

"You can't set low speed limits because what if Usain Bolt sprints at 30 mph down your street?!?" As Jabberwocky suggested, just because something is possible, it doesn't mean it is likely. But when you strap a motor to something, that changes the likelihood, or prevalence, a lot.

It's funny, that of all the criticisms one could make of the ebike industry, for conspiratorial behavior, only the false ones are being dredged up. Here's a couple that are actually true: near monopoly of Bosch in Europe in terms of market share, proprietary battery standards that devalue used bikes and inflate prices of replacements. A subsidy bill to boost adoption (E-BIKE act) when bikes are already sold out, so the subsidy is pointless for the near term.

My Usain Bolt statement was just intended to show that assist limits are a bit nonsensical. That was not a conspiracy point...just intended to get people thinking a bit. Why is it so hard for people to allow themselves to think that a "low power electric bicycle" is NOT a motor vehicle and CAN be just "use" regulated as a bike. Isn't that what an advocasy group should be striving for .... that's what my petition is striving for and what we did have from 2002 till the 3-class wrench was thrown in (and it was not for clarity or safety and it's not a conspiracy to state the truth).

I think the Durado ebike battery is about the only battery format that is somewhat standard across multiple brands. The battery is the ebike industries "consumable" (just like ink to the printer industry). As you point out, proprietary batteries devalue 2nd hand ebikes at the very minimum.

I do have a conspiracy theory on the tax subsidy bill - that it was a way to get federal level acceptance of the 3-class system (the bill should be tied to CPSC definition compliance as they own 1st sale configuration of ebikes, not state 3-class).

 

[Ken M]

Insurance is required primarily because insurance was already required for mopeds going the same speed. I'm not saying it's a good idea per se, to require insurance on s pedelecs, but it's not some requirement out of nowhere. Maybe the moped companies wanted it that way, but it's not out of character.

As for a survey, of course people want a simpler law, but they haven't thought thru issues like access to parks, which you continue to ignore or dismiss.

Insurance requirements on class 3 / speed pedelecs in Europe is like an anti-erection pill for ebikes. If the insurance industry does that to ebikes assisting faster than 20mph (they did it to any going faster than 15mph in Europe) then flush the most effective urban mobility solution EVER down the toilet. NONE of us (unless you work in that ??? field) should want that industry given an open door invite into ebikes - even if some trail access is lost.

No trail access should be lost because assist speed is NOT the problem on trails (hikers have historically complained that bikes on trails is a problem, nothing new with ebikes....they will always whine so maybe trails should be "walking/hiking only" or "bike only" ... just give the whiny walkers far less trails is my solution). Let's face it the walking lobby should be much less powerful as the ebike lobby so take away their trains since they are trying to take away biking trails. We can put some tread mills near the trail parking lots to appease them.

 

[Asher]

(hikers have historically complained that bikes on trails is a problem, nothing new with ebikes....they will always whine so maybe trails should be "walking/hiking only" or "bike only" ... just give the whiny walkers far less trails is my solution).

Translation: "I don't care if what I propose causes problems for other people as long as I get my way."

 

[jabberwocky]

No trail access should be lost because assist speed is NOT the problem on trails (hikers have historically complained that bikes on trails is a problem, nothing new with ebikes....they will always whine so maybe trails should be "walking/hiking only" or "bike only" ... just give the whiny walkers far less trails is my solution). Let's face it the walking lobby should be much less powerful as the ebike lobby so take away their trains since they are trying to take away biking trails. We can put some tread mills near the trail parking lots to appease them.

It will apparently surprise you to learn this, but going to the advocacy table with “f*ck other user groups, take their s*it away and give it to me” is an extremely ineffective approach.

 

[Ken M]

Translation: "I don't care if what I propose causes problems for other people as long as I get my way."

Do you understand that was supposed to be humorous? I have hiked a lot and trail biked a lot. 95% of either just coexist happily. It is sometimes hard to take the vocal minority very serious sometimes.

I commuted over 5,000 miles on an ebike one year a couple years ago. I had two issues with walkers on multi-use sidewalks/paths. Both times the walker insisted to remain in the middle of the path as I approached (I had a ringer on my bike just to avoid ever startling anyone by riding fast past them). Both times they literally leaned into my path to force me off the paved path. I ignored it but it's an example that maybe it's not the bikers that are the bad guys in the reports on hiker/biker issues.