Are the class modes a point of sale requirement? I'm sure the OEMs are not going to allow the states or consumers to have open access to programming the controller so sure seems like those modes are an element of the ebike when it comes out of the box even though the CPSC does not require it and it's more stringent than the federal definition.Because its not a point of sale requirement? The code here in VA just says "All class three electric power-assisted bicycles shall be equipped with a speedometer that displays the speed the bicycle is traveling in miles per hour." It doesn't say they are required to be sold with one. Something like a basic Planet Bike or Cateye wheel magnet computer would suffice, as would any of the common GPS devices made by Wahoo or Garmin. I read that as "if you get a speeding ticket on your class 3, you can't use "I didn't know how fast I was going!" as a defense"
The Creo is definitely not marketed as a general purpose ebike, it is designed (and priced) for people who want a high-end road bike experience, but with assist. That crowd absolutely wants a clean cockpit, and almost certainly already have some sort of gps bike computer. I can't speak to how Specialized thinks of it internally or what their market research says, but I'd guess that very few people buy Creos and run it without something that displays speed. Specialized does make a compatible display unit that is relatively (compared to the bike) inexpensive.
Obviously a speedometer can be added to any bike after 1st sale but tell me how the programming for the classes can be added. Do those 3 classes improve product safety? Are they really justified for "use" regulations just because some make that claim while other states like Oregon get by without them? I really think you guys are trying to pull a rabbit out of a hat. My petition just brings up what I think is state legislative capture of a product that CPSC product regulates and the states are suppose to just stick to regulating its "use" (they did not need to redefine more stringently for that purpose and if they did why did it take them 12+ years to decide they needed to?
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