US National Park Service Announces Policy for Electric Bicycle Use in National Parks

[gkgeiger]

Done

 

[J.R.]

The National Park Service are inviting public feedback on the revised ebike regulations, submit your comments by June 8 https://www.nps.gov/subjects/biking/e-bikes.htm

For any of us who ride, or wish to ride e-bikes in National Parks, THIS IS OUR OPPORTUNITY TO EXPRESS OUR OPINION!

From the comments I've reviewed so far, the trend is NOT going in our favor! Let's not waste this chance to voice our opinion!

My thanks to Dewey for spotting and posting this. IMO, it is important enough to warrant it's own separate thread.

Here is a direct link to the comment page: https://www.regulations.gov/document?D=NPS_FRDOC_0001-0136

Read the instructions first, then click on the blue oval that says "comment" in the upper right of the page. By all means, VOICE YOUR OPINION!!

Thanks guys! I passed this on to 5 other ebikers too.

 

[Dewey]

Thanks to all who write in favor, the 72 comments submitted so far are the usual mix of ebike enthusiasts and haters much of which is knee-jerk reaction based on nothing more than uninformed opinion, let’s contribute our experience of the benefits of ebikes for recreation, health, and transportation https://www.regulations.gov/docketB...sb=commentDueDate&po=0&dct=PS&D=NPS-2020-0001

 

[AHicks]

Just added my comment:

"I think concern over how a bike ridden by a senior is a waste. I would ask that seniors on an e-bike be allowed to ride them anywhere a conventional bike is allowed without class I, II, or III, distinction. This at the very least."

This was the first I had heard about it. Happy to contribute. -Al

 

[Mr. Coffee]

Just added my comment:

"I think concern over how a bike ridden by a senior is a waste. I would ask that seniors on an e-bike be allowed to ride them anywhere a conventional bike is allowed without class I, II, or III, distinction. This at the very least."

With respect, that is probably not the most persuasive post and from a practical standpoint will do little to guide the NPS to a wise decision. I think it better to understand what the NPS is going to care about and address those concerns.

In short, this decision is going to be about three things:

1. Safety. If you can persuade the NPS that e-bikes are safe (or unsafe) for visitors that will have a lot of weight.
2. Protecting Resources. If you can persuade the NPS that e-bikes will damage (or not damage) park resources that will also have a great deal of weight.
3. Experience of Other Visitors. If you can show the NPS that e-bikes will harm (or not harm) the experience of other park visitors they are obligated to take that into account.

I do have some experience working with land management agencies like the NPS on visitor access issues and these are the points that repeatedly come up. So if you can package your response in that language your comment will have greater weight.

My own opinion is that the dominant safety issue for addressing e-bikes is going to be their speed, and the perception (unjustified) that they are much faster than cyclists on acoustic bikes. The dominant resource and visitor experience issue is going to be noise -- and we all know that even a noisy e-bike isn't that noisy, and on the average tire and drivetrain noise are comparably noisy.

 

[AHicks]

With respect, that is probably not the most persuasive post and from a practical standpoint will do little to guide the NPS to a wise decision. I think it better to understand what the NPS is going to care about and address those concerns.

In short, this decision is going to be about three things:

1. Safety. If you can persuade the NPS that e-bikes are safe (or unsafe) for visitors that will have a lot of weight.
2. Protecting Resources. If you can persuade the NPS that e-bikes will damage (or not damage) park resources that will also have a great deal of weight.
3. Experience of Other Visitors. If you can show the NPS that e-bikes will harm (or not harm) the experience of other park visitors they are obligated to take that into account.

I do have some experience working with land management agencies like the NPS on visitor access issues and these are the points that repeatedly come up. So if you can package your response in that language your comment will have greater weight.

My own opinion is that the dominant safety issue for addressing e-bikes is going to be their speed, and the perception (unjustified) that they are much faster than cyclists on acoustic bikes. The dominant resource and visitor experience issue is going to be noise -- and we all know that even a noisy e-bike isn't that noisy, and on the average tire and drivetrain noise are comparably noisy.

Also with respect, I disagree. I believe seniors, many of which would not be on a conventional bike due to health and fitness issues, will be most affected by ANY e-bike limitations.

 

[6zfshdb]

I'm a little confused. Did they change anything since August 2019 or are they just inviting public feedback on those revised regs?

Nothing has been changed yet. The NPS is asking for public feedback. This is our chance to voice our opinion. Every submission is important so if you haven't already done so, please add a comment via the link provided above.

 

[Dewey]

I think it better to understand what the NPS is going to care about and address those concerns...I do have some experience working with land management agencies like the NPS on visitor access issues and these are the points that repeatedly come up. So if you can package your response in that language your comment will have greater weight.

Thanks, the concerns you point to about visitor safety and property damage are mentioned in the NPS manual implementing procedures for the National Environmental Policy Act (NEPA) https://www.doi.gov/sites/doi.gov/files/elips/documents/chapte1_16.doc

So with a view to addressing these concerns, here is what I wrote:

I support permitting Class 1-3 ebikes to ride where bicycles are permitted in National Parks. Addressing three concerns of
1. Safety: Is ebiking a safe activity for Park visitors?
2. Protecting resources: will ebiking damage Park resources?
3. Experience of visitors: does ebiking harm or benefit the Park visitor experience?

1. Safety: In 2015 ebike researcher Chris Cherry at the University of Tennessee found "with few exceptions, riders of e-bikes behave very similarly to riders of bicycles" and "average on-road speeds of e-bike riders (13.3kph) were higher than regular bicyclists (10.4kph) but shared use path (greenway) speeds of e-bike riders (11.0kph) were lower than regular bicyclists (12.6kph), source: https://pubmed.ncbi.nlm.nih.gov/26093098/. A German study captured real-time riding data over 17,000km using telemetry sensors and cameras on pedelecs (Class 1 equivalents) and speed pedelecs (Class 3 equivalents) on road and bicycle infrastructure confirmed a mean average speed differential of 2 kmh between pedelecs and cyclists and 9 kmh between speed pedelecs and cyclists, source: http://dx.doi.org/10.1016/j.ssci.2015.07.027. Another German study using similar data capture technology identified no data to suggest ebikes are more likely than pedal bicycles to be involved in pedestrian collisions on Multi-use paths, source: http://dx.doi.org/10.1016/j.trf.2016.06.010.

2. Protecting resources: In 2015 the International Mountain Biking Association conducted a study that found no significant additional damage to Mountain Bicycling trails from ebikes compared to regular mountain pedal bikes, source: https://b.3cdn.net/bikes/c3fe8a28f1a0f32317_g3m6bdt7g.pdf

3. Experience of visitors: In 2017 Chris Cherry reported physical activity levels among ebikers and cyclists are similar, ebikers ride further distances, and report higher levels of enjoyment from cycling, source: http://dx.doi.org/10.1016/j.jth.2017.06.002. Other studies have shown improved cognitive functioning in older adults who ride ebikes, source: https://www-ncbi-nlm-nih-gov.proxygw.wrlc.org/pubmed/30785893. In addition to the health benefits, sections of mixed use bicycle/pedestrian infrastructure in National Parks form critical links for regional bicycle commuters, for example the sidewalks of Memorial Bridge (part of the George Washington Memorial Parkway) are, since August 2019, the only legal safe traffic-separated route for riding an ebike to cross the Potomac River between Arlington, VA and Washington, DC.

 

[6zfshdb]

Thanks, the concerns you point to about visitor safety and property damage are mentioned in the NPS manual implementing procedures for the National Environmental Policy Act (NEPA) https://www.doi.gov/sites/doi.gov/files/elips/documents/chapte1_16.doc

So with a view to addressing these concerns, here is what I wrote:

I support permitting Class 1-3 ebikes to ride where bicycles are permitted in National Parks. Addressing three concerns of
1. Safety: Is ebiking a safe activity for Park visitors?
2. Protecting resources: will ebiking damage Park resources?
3. Experience of visitors: does ebiking harm or benefit the Park visitor experience?

1. Safety: In 2015 ebike researcher Chris Cherry at the University of Tennessee found "with few exceptions, riders of e-bikes behave very similarly to riders of bicycles" and "average on-road speeds of e-bike riders (13.3kph) were higher than regular bicyclists (10.4kph) but shared use path (greenway) speeds of e-bike riders (11.0kph) were lower than regular bicyclists (12.6kph), source: https://pubmed.ncbi.nlm.nih.gov/26093098/. A German study captured real-time riding data over 17,000km using telemetry sensors and cameras on pedelecs (Class 1 equivalents) and speed pedelecs (Class 3 equivalents) on road and bicycle infrastructure confirmed a mean average speed differential of 2 kmh between pedelecs and cyclists and 9 kmh between speed pedelecs and cyclists, source: http://dx.doi.org/10.1016/j.ssci.2015.07.027. Another German study using similar data capture technology identified no data to suggest ebikes are more likely than pedal bicycles to be involved in pedestrian collisions on Multi-use paths, source: http://dx.doi.org/10.1016/j.trf.2016.06.010.

2. Protecting resources: In 2015 the International Mountain Biking Association conducted a study that found no significant additional damage to Mountain Bicycling trails from ebikes compared to regular mountain pedal bikes, source: https://b.3cdn.net/bikes/c3fe8a28f1a0f32317_g3m6bdt7g.pdf

3. Experience of visitors: In 2017 Chris Cherry reported physical activity levels among ebikers and cyclists are similar, ebikers ride further distances, and report higher levels of enjoyment from cycling, source: http://dx.doi.org/10.1016/j.jth.2017.06.002. Other studies have shown improved cognitive functioning in older adults who ride ebikes, source: https://www-ncbi-nlm-nih-gov.proxygw.wrlc.org/pubmed/30785893. In addition to the health benefits, sections of mixed use bicycle/pedestrian infrastructure in National Parks form critical links for regional bicycle commuters, for example the sidewalks of Memorial Bridge (part of the George Washington Memorial Parkway) are, since August 2019, the only legal safe traffic-separated route for riding an ebike to cross the Potomac River between Arlington, VA and Washington, DC.

Excellent!

Considerable effort went into making your comment.

Thanks Dewey!!

 

[6zfshdb]

This is the comment I submitted. It isn't as comprehensive as Dewey's but I think it represents the senior / handicapped point of view:


"My wife and I have been riding trails in our wonderful National Parks for over 30 years on our conventional bikes. We are now seniors and partially disabled to the point where we can no longer ride regular bicycles. Three years ago, we bought a pair of e-bikes which enabled us to get out and ride once again!

We have been riding our e-bikes alongside conventional bikes on many multi use trails with absolutely no conflict whatever. E-bikes do not go any faster or cause any more surface damage than regular bikes. If fact, we are often passed by groups of riders on conventional racing bikes. It is the rider that causes conflict, not the bike.

We talk to many other trail riders and it appears the main objection to e-bikes is one of vanity. Younger, more fit riders seem to feel threatened by the fact that seniors can now keep pace with the youngsters. For some reason, they don't think it's "fair". I suspect that much of the anti e-bike sentiment will fade with time as these younger riders become seniors.

Please don't ban e-bikes and deprive seniors & handicapped folks from enjoying our great National Park system!"

Others may have a different point of view. Whatever it is, please, use the links posted above and LEAVE YOUR COMMENT !!

 

[Dewey]

It is the rider that causes conflict, not the bike.

Agreed. Until NPS permitted Class 1-3 ebikes in Parks last fall, the trend among local regulations has been to enact bans on Class 3 ebikes riding on bicycle infrastructure. Yet reading comments on my local bicycle forum and on here from Class 3 commuters riding in from further out, they ride appropriately according to conditions ie they utilize the Class 3 speed to more efficiently reduce time spent riding on streets, then adhere to trail speed limits when riding on traffic-separated bicycle infrastructure when closer in and need to cross bridges using the sidewalks or ride in traffic using bike lanes. I have no problem with NPS trail speed limits or the currently worded no-throttle use for Class 2. It would be nice for NPS to continue this to enable studies to be done that provide evidence that regulating rider behavior is the right approach.

 

[Dallant]

I hope that this idea moves forward! I was very disappointed a couple of years ago when we went to Acadia National Park in Maine and was planning to rent an electric bike so I could kinda keep up with the younger riders in our family. The local shop had several available but when they found out where I was taking it, they refused to rent it to me because of pressure from Park officials to keep ebikes off the trails. Ruined Two days of the trip for me.

 

[Ravi Kempaiah]

Good news: the final regulations will be published soon and it includes E-bikes upto 750W in power. [Link below]

Electric Bicycles (e-bikes) in National Parks - Biking (U.S. National Park Service)

Learn more about e-bikes in the national parks.

www.nps.gov

 

[FlatSix911]

Good news: the final regulations will be published soon and it includes E-bikes upto 750W in power. [Link below]

Electric Bicycles (e-bikes) in National Parks - Biking (U.S. National Park Service)

Learn more about e-bikes in the national parks.

www.nps.gov

View attachment 67339

This is indeed good news.

The devil is in the details as to which specific areas will be designated for Class 1 EBikes... sounds like this will be left up to the local park superintendent.

The regulations also appear to restrict the use of Class 2 Throttle Ebikes to roads accessible to public motor vehicles... very limited use in National Parks.

 

[Dewey]

The regulations also appear to restrict the use of Class 2 Throttle Ebikes to roads accessible to public motor vehicles... very limited use in National Parks.

The wording bans throttle use "for an extended period of time without pedalling", so I interpret that to mean it does not ban Class 2 ebikes from riding with pedal assist. It is a default throttle use ban not a Class 2 ban unless a park superintendent writes that into an individual National Park's Compendium of regulations. For example the George Washington Memorial Parkway covers land in two Virginia counties and a city in VA, plus some land in the District of Columbia, where under a September 2019 Record of Determination "allows (Class 1-3) E-bikes where traditional bicycles are allowed," and for Class 2 ebikes the relevant wording is " Except where use of motor vehicles by the public is allowed, using the electric motor to move an e-bike without pedaling is prohibited," so no throttle use.

 

[FlatSix911]

The wording bans throttle use "for an extended period of time without pedaling", so I interpret that to mean it does not ban Class 2 ebikes from riding with pedal assist.

It is a default throttle use ban not a Class 2 ban unless a park superintendent writes that into an individual National Park's Compendium of regulations.

I agree that the regulations are open to interpretation, but I think the default prohibits Class-2 on trails and limits them to public roads... how else is a throttle ban enforced?

 

[Dewey]

I agree that the regulations are open to interpretation, but I think the default prohibits Class-2 on trails and limits them to public roads... how else is a throttle ban enforced?

Then it is up to individual Park superintendents to write a Class 2 ban into the Compendium, the default wording permits Class 1-3 ebikes to ride under motor power where pedal bicycles are permitted provided the operator is using pedal assist.

 

[FlatSix911]

Then it is up to individual Park superintendents to write a Class 2 ban into the Compendium, the default wording permits Class 1-3 ebikes to ride under motor power where pedal bicycles are permitted provided the operator is using pedal assist.

I hope your interpretation is correct, however, I afraid most superintendents may disagree and go with a more conservative approach.

Do the regulations restrict how the electric motor may be used?
Yes. The intent of the regulations is to allow visitors to use e-bikes for transportation and recreation in a manner similar to traditional bicycles.
As a result, the regulations prohibit operators of Class 2 e-bikes from using the motor to propel the e-bike for an extended period of time without pedaling, except in locations that are open to public motor vehicle use.

 

[Dewey]

superintendents may disagree and go with a more conservative approach.

Yes they may, National Park Superintendents have the power to enact a Class 2 ban provided they write that into the Park Compendium. At the State level the 3-class model ebike legislation similarly permits trail operators, state, and local govt, to enact or lift a local ebike ban on riding on sidewalks, paths, or trails. This year on the East Coast we've seen example of both approaches, following Virginia's adoption of the 3-class ebike law with its permissions Arlington County revised it's 40-year old trail ban on Motorized bicycles to permit ebikes, whereas in New York City a small but politically influential group of wealthy residents (members of the Hudson River Park Friends) obliged two state senators representing Manhattan to threaten to reject passage of a modified version of the 3-class ebike bill in the NY Assembly until they wrote in a total ebike ban on the Hudson River Greenway which the Friends are reportedly currently asking NYPD to enforce. My main concern about the NPS regulations is the change was initiated by order from the Interior Secretary, presumably with a change of administration could just as easily be changed back.

 

[Ravi Kempaiah]

Yet reading comments on my local bicycle forum and on here from Class 3 commuters riding in from further out, they ride appropriately according to conditions ie they utilize the Class 3 speed to more efficiently reduce time spent riding on streets, then adhere to trail speed limits when riding on traffic-separated bicycle infrastructure when closer in and need to cross bridges using the sidewalks or ride in traffic using bike lanes.

I agree. If the riders are responsible then superintendents and park rangers don't really bother checking if someone's riding a Class 1 or 2 or do they have speed delimiter dongle in their Class 1 etc.
They have more pressing things to attend to.

I am glad NPS is finalizing their regulations to allow E-bikes.