What should be allowed under EAPC (Electric Assist Pedal Cycle) rules?

[Bletchleyite]

I do wish we allowed a proper top speed on our ebikes though. There's a perfectly sensible half way house between these courier mopeds disgusied as bikes and our current fairly weedy e-bikes in having something like they have in the US where you have e-bikes permitted to be motoring to the high 20s mph wise. I can understand why they might be problematic in London, but up here they'd be brilliant.

I wouldn't be opposed to such vehicles existing as a separate classification a bit like the Dutch Bromfiets. But you should have to have insurance and a helmet (cycle style rather than motorcycle style, because a motorcycle style helmet wouldn't be great if you wanted to assist it by pedalling) for these, because they're basically just an electric version of a Class AM (49cc) moped.

For EAPCs I'd increase the permitted speed to 20mph, because that allows you to ride with traffic in urban areas (particularly in Wales) and so improves safety for the cyclist. It's also a speed fairly easily attainable by a fit adult on a road bike and so a typical speed you'll get an unpowered cyclist going. But not beyond that I'd say.

I wonder would increasing the EAPC speed to 20mph mean more couriers would use legal ones? I sort of doubt it.

 

[renegademaster]

I don't really see the safety reason why 15mph not pedalling is more dangerous in any substantive way than 15mph pedalling. It's just a regulatory hangover of decades old EU regulations. Ebikes, even with non compliant limiters, are substantially lighter than petrol AMs so it doesn't feel fair to regulate them exactly the same.

A lot of the debate around this seems to be driven by prejudices, earned or unearned, about immigrant delivery app riders. Clamping down on ebikes isn't going to make the highway code knowledge of someone who has only been here a year any better.

 

[Harpers Tate]

I think it may be important to clarify that a (legal) EAPC only has the assistance limited to 15.5 mph. In fact one can, of course cycle faster, at any speed you are capable of achieving given gradienbt, wind and your leg-power. There is no speed limit per se; only a limit to the assistance.

Also, (apparently with some limited exceptions, rare in fact at the moment), one has to be pedalling in order for the motor to do anything, So "15mph not pedalling" would mean you were going downhill; that is all. If any effort is needed to maintain that speed, then the rider pretty much has to supply at least some of it.

And in any case, the continuous rated power (for a legal EAPC) can't exceed 250w as it stands and I see no current exceptions to that. And that's not enough to self-propel in anything other than very "easy" (read, downhill, strong tailwind, etc.), conditions. So it's not just a matter of easing the assist limit and/or allowing for no rider effort; it becomes a matter of increasing allowed power output as well.

 

[Bletchleyite]

A lot of the debate around this seems to be driven by prejudices, earned or unearned, about immigrant delivery app riders. Clamping down on ebikes isn't going to make the highway code knowledge of someone who has only been here a year any better.

This is true. The dangerous riding carried out by them has just transferred across from dangerous riding of petrol 49cc mopeds on L plates. And that (or the lack of enforcement thereof) is a symptom of the move from on the ground policing to camera based policing.

I'm not to be fair opposed to higher power/speed electric bicycles, but they should be seen as motorcycles in law which allows easier enforcement because of e.g. registration plates. The fastest a typical person can ride a pushbike is about 20mph, so that seems a sensible ceiling for EAPCs; of course there are those who can ride a road bike much faster, but those people are by and large not the problem.

 

[renegademaster]

has just transferred across from dangerous riding of petrol 49cc mopeds on L plates

You can drive a 55mph 125cc with just a CBT and they aren't hard to pass. Plus I think the police do not have an easy way of enforcing you actually having one, since it's still on an archaic paper based system and can't be linked to your licence or registration number, nor are you obliged to have it on you. At least that's what I heard from a CBT assessor.

I think it may be important to clarify that a (legal) EAPC only has the assistance limited to 15.5 mph. In fact one can, of course cycle faster, at any speed you are capable of achieving given gradienbt, wind and your leg-power. There is no speed limit per se; only a limit to the assistance.

Also, (apparently with some limited exceptions, rare in fact at the moment), one has to be pedalling in order for the motor to do anything, So "15mph not pedalling" would mean you were going downhill; that is all. If any effort is needed to maintain that speed, then the rider pretty much has to supply at least some of it.

And in any case, the continuous rated power (for a legal EAPC) can't exceed 250w as it stands and I see no current exceptions to that. And that's not enough to self-propel in anything other than very "easy" (read, downhill, strong tailwind, etc.), conditions. So it's not just a matter of easing the assist limit and/or allowing for no rider effort; it becomes a matter of increasing allowed power output as well.

I may have phrased my post poorly, but my point still stands. Being electrically propelled with a token movement of the pedals does not make anything safer. The power limit is a defacto weight limit.

 

[Bletchleyite]

I may have phrased my post poorly, but my point still stands. Being electrically propelled with a token movement of the pedals does not make anything safer. The power limit is a defacto weight limit.

I don't have an issue with EAPCs being rideable with a throttle (and I'd include e-scooters capable of under 20mph in the same rules, personally). I do have an issue with their assisted top speed being in excess of 20mph. That's a motorcycle. I'm all for electric motorcycles, I think they're a great idea, but I equally think the requirements for insurance, CBT, helmet, registration plates etc should be the same as for a petrol vehicle with the same capabilities, give or take that if you expect them to be pedalled at any point the mandatory helmet would probably be better as a cycle one rather than a motorcycle one. They could even come under the existing AM category with some small changes to that.

 

[BingMan]

And in any case, the continuous rated power (for a legal EAPC) can't exceed 250w as it stands

That is the continuous rated or "nameplate" power of the motor. I have measured my legal e-bike and it is giving almost 400w on top setting.
The 250 w nameplate rating is based on 24hours per day in hot conditions but it can safely pull more when used intermittently with good cooling

 

[Ediswan]

That is the continuous rated or "nameplate" power of the motor. I have measured my legal e-bike and it is giving almost 400w on top setting.
The 250 w nameplate rating is based on 24hours per day in hot conditions but it can safely pull more when used intermittently with good cooling

Source please. Not saying you are wrong, I have been looking for an applicable definition of 'continuous rated power'.

 

[BingMan]

Source please. Not saying you are wrong, I have been looking for an applicable definition of 'continuous rated power'.

Generative AI tells me

In the context of electric motors, "continuous rated power" refers to the maximum power the motor can reliably and continuously output without overheating or exceeding its safety limits under normal operating conditions.

Here's a more detailed explanation:

• What it means:
  Continuous rated power is the power level at which a motor can operate for extended periods (hours, days, or even continuously) without experiencing excessive temperature rise or damage.
  
• Why it matters:
  Understanding the continuous rated power is crucial for selecting the right motor for an application, ensuring that the motor can handle the load consistently and reliably.
  
• Continuous vs. Peak/Short-Term Power:
  Motors can often handle higher power levels for short periods (peak power), but operating at these levels continuously can lead to overheating and failure. The continuous rated power is the power level that the motor is designed to handle for prolonged use.
  
• How it's measured:
  The continuous rated power is usually specified in watts (W) or horsepower (hp) and is typically found on the motor's nameplate.

 

[Egg Centric]

That is the continuous rated or "nameplate" power of the motor. I have measured my legal e-bike and it is giving almost 400w on top setting.
The 250 w nameplate rating is based on 24hours per day in hot conditions but it can safely pull more when used intermittently with good cooling

This seems like you could just plate a 2kw motor as 250w and say put a hardware lock to prevent the power being used more that 23 hours a day. Not saying it's not right but if it is why hasn't someone done this!

 

[JamesT]

Source please. Not saying you are wrong, I have been looking for an applicable definition of 'continuous rated power'.

The legislation https://www.legislation.gov.uk/uksi/1983/1168/regulation/2/made says:

2. In these Regulations—

“continuous rated output” has the same meaning as in the 1971 British Standard;

Unfortunately British Standards cost money to read.

There was a consultation on aligning our regulations with the EU ones, which state: https://eur-lex.europa.eu/eli/reg/2013/168/oj/eng

(35)
‘maximum continuous rated power’ means the maximum thirty minutes power at the output shaft of an electric engine as set out in UNECE regulation No 85;

 

[Crithylum]

This seems like you could just plate a 2kw motor as 250w and say put a hardware lock to prevent the power being used more that 23 hours a day. Not saying it's not right but if it is why hasn't someone done this!

My digging has found the limit at 30 minutes.
https://www.legislation.gov.uk/uksi/2015/24/regulation/2/made (the amendments changed the maximum power rating to EU definitions)
https://www.legislation.gov.uk/eur/2013/168/article/3 (see definition 35)
Which then links to:
https://op.europa.eu/en/publication-detail/-/publication/44471446-bc46-44f0-bc97-0de997b18106 (2.5, can’t quote as on mobile)

Regulation No 85 of the Economic Commission for Europe of the United Nations (UN/ECE) — Uniform provisions concerning the approval of internal combustion engines or electric drive trains intended for the propulsion of motor vehicles of categories M a

op.europa.eu

Further reading of the regulations makes it seem that this is the process for determining “maximum 30 minutes power” under 5.3.2:

1. Manufacturer determines a number
2. Test ensures that the motor can achieve determined number for 30 minutes

My interpretation is that under 5.3.2 (as long as a software limit is imposed after 30 minutes), literally anything is allowed in the first 29.

The issue with this tactic is that 2.5 references 5.3.1, not 5.3.2. 5.3.1 requires it to tested at “full setting of its power controller. However, 5.3.1 states that the test may last for no longer than 5 minutes (before a 2 hour cool-down period). So using 5.3.1 is very wishy washy.

Annex 6, which is referenced as the conditions of the tests, is written for electric cars, not bikes. It also appears to be written in a way assuming a manufacturer wants to artificially inflate their numbers, not deflate. It also states that any variable fans should be set to minimum speed. I could easily envisage a situation where in the lab the motor overheats at 250w, however, with airflow (from moving) it can easily sustain much more than 250w.

TLDR: regulations do not have the e-bike “power underestimation” in mind, so the 250w limit can be easily cheesed. However as 250w is enough for 25km/h, I think this loophole is not particularly useful (however, the government website says electrical assistance must cut off, I will probably look into this loophole at some point).

 

[BingMan]

TLDR: regulations do not have the e-bike “power underestimation” in mind, so the 250w limit can be easily cheesed. However as 250w is enough for 25km/h, I think this loophole is not particularly useful (however, the government website says electrical assistance must cut off, I will probably look into this loophole at some point).

"50w might be enough for 25kph on the level but extra power enables you to tackle steeper hills at reasonable speed

 

[MikeFromLFE]

I wouldn't be opposed to such vehicles existing as a separate classification a bit like the Dutch Bromfiets. But you should have to have insurance and a helmet (cycle style rather than motorcycle style, because a motorcycle style helmet wouldn't be great if you wanted to assist it by pedalling) for these, because they're basically just an electric version of a Class AM (49cc) moped.

The standards for bicycle helmets are such that they are very limited. The standard is EN1078 - this only tests the helmet for an impact at 12mph onto something like a kerbstone. If you are going to argue for helmets over the existing assisted limit then you need to argue for motorcycle helmets (or no helmets). Commonly used cycle helmets are little more than homeopathy.

 

[Bletchleyite]

The standards for bicycle helmets are such that they are very limited. The standard is EN1078 - this only tests the helmet for an impact at 12mph onto something like a kerbstone. If you are going to argue for helmets over the existing assisted limit then you need to argue for motorcycle helmets (or no helmets).

I suppose a new standard could be developed for a ventilated helmet with motorcycle like capability. But it should be fairly obvious that a motorcycle helmet as they presently exist isn't suitable for riding something where you will still pedal, as they are not very well ventilated because normal motorcycling isn't as physical.

Commonly used cycle helmets are little more than homeopathy

...is frankly a load of rubbish, I'm afraid. You stated yourself what they're designed for, but it's nonsense to suggest they'd have no effect at all in other situations, and indeed because cycling is a low speed activity most accidents indeed do involve a low speed impact with the ground, having been knocked off or gone over the bars, not the head being hit by a car or similar.

 

[BlueLeanie]

Well, this six wheeler articulated vehicle, with dual 250W motors, 90cm wide, 5 metres long, that can haul 350Kg of Cargo, is an electrically assisted bicycle and fully UK cycle lane legal.

And a video of it in action around London

I'd love to see a "British Weather" enclosed version of this open to the weather "Surrey" or "Resort" bike that allows up to four adults to pedal (2x2) with electrical assistance, plus 2 additional passengers + 2 toddler spaces complete with a sunshade.

Maybe something Dolly or original Herbie sized? Just imagine two athletic couples popping into the cinema of the evening, being able to leave it anywhere in the City Centre. Then pedal home on the shortest route without fear of LTNs, CPZ, parking tickets, parking fines

 

[Bletchleyite]

Well, this six wheeler articulated vehicle, with dual 250W motors, 90cm wide, 5 metres long, that can haul 350Kg of Cargo, is an electrically assisted bicycle and fully UK cycle lane legal.

How is a cycle with *dual* 250W motors, thus 500W output, a legal EAPC?

I can't decide what I think of those vehicles, though. They are clearly more environmentally friendly than a diesel Transit van, but equally they aren't very big so you need a few of those per Transit, and like those really annoying rickshaw things you get around central London those are much more likely to get in the way of other vehicles, most notably buses when ridden in bus lanes and also when inevitably parked on the pavement. I kind of err towards the side that they're taking the mick, but it would be a bit hard to put those in another classification without catching other EAPCs or more normal e-cargo bikes, or things like bikes with a child trailer. OK, trikes also take up more space, but equally they aren't particularly mainstream and are usually ridden by people who couldn't ride a bicycle due to medical/disability reasons, so are more important for accessibility purposes.

 

[BlueLeanie]

How is a cycle with *dual* 250W motors, thus 500W output, a legal EAPC?

Perhaps the driver cab and the articulated trailer are considered to be two separate vehicles? Apparently the law requires the individual to "pedal" to deliver power, but it doesn't actually require the pedals to be mechanically connected to the wheels, they can just turn an alternator.

They have so much potential. At 90cm wide, they could accommodate a wheelchair. You could put two kids in the trailer in proper isofix car seats, instead of those terrifying Dutch crates.

We could even have them on Co-op daytime TV as hearses! "When Dave passed...". They could zoom down cycle lanes and get to the Church or Crem in superfast time.

 

[jon0844]

We need to sort out the rules for things like the above, as clearly they're a benefit in many ways but could also become a nightmare if ridden along narrower shared cycle/pavements at speed - given you'd need very decent braking. If Amazon and the like start using these in large numbers, and drivers are still on extremely tight deadlines, then it's going to result in all sorts of problems.

And I say this as someone who thinks cargo bikes are very, very useful for last mile deliveries in busy areas. The problem is I also know how they'll be used by some people, and one of those versus a child that deviates from walking in a straight line, or a pet on a lead that wanders etc is not going to end well.

Better to get ahead of things now, as I want to see more of these vehicles and all that will happen is we have some people seriously hurt or killed, and then there will be campaigns to ban them entirely.

 

[Bletchleyite]

Better to get ahead of things now, as I want to see more of these vehicles and all that will happen is we have some people seriously hurt or killed, and then there will be campaigns to ban them entirely.

Indeed. Overall I'm inclined to wonder if these should be in their own category and require registration plates (to allow enforcement of bad parking) and perhaps insurance (because if they hit something or someone it'll be more of an issue than an average bicycle or traditional cargo cycle). You could get that category free with class A/AM or B to avoid needing to do another test. They're really just the equivalent of the "moped van" things you sometimes see doing postal deliveries in places like Switzerland.

Question is how to define them I guess.

 

[jon0844]

We've been monumentally awful at keeping ahead of the emerging technology that has allowed things like motorised pedal cycles, electric motorcycles and electric cargo bikes/vans.

It's because of this that we see EAPCs caught up in the media when the issues are illegal bikes with powerful motors, throttles and no restriction on speed. Most people seem to think they're the same as an EAPC you buy in Halfords, and then go after the owners as being lunatics or causing a danger to others (like they're all going to catch fire, which although a non-zero risk isn't the same as the home-grown Temu-like conversions).

Enforcement is also terrible. Sure, we see the results of stings and perhaps they're increasing them in some locations (like city centres for mostly delivery drivers) but overall, the police show little interest most of the time.

 

[BlueLeanie]

Indeed. Overall I'm inclined to wonder if these should be in their own category and require registration plates (to allow enforcement of bad parking) and perhaps insurance (because if they hit something or someone it'll be more of an issue than an average bicycle or traditional cargo cycle). You could get that category free with class A/AM or B to avoid needing to do another test. They're really just the equivalent of the "moped van" things you sometimes see doing postal deliveries in places like Switzerland.

Question is how to define them I guess.

With the sheer volume on the road now, perhaps every bicycle that is used commercially should be prohibited from shared spaces, be required to display licence plates, and have third party insurance?

(That should include bicycles used by Nannies and au-pairs to cart children about.)

And having just walked back from the gym, I wouldn't want to be on some "shared spaces" on wooden bridges over streams and small rivers at the same time as that vehicle! Vehicle, driver, and up to 350Kg of cargo along with other pedestrians could well be over the planned load.

 

[renegademaster]

With the sheer volume on the road now, perhaps every bicycle that is used commercially should be prohibited from shared spaces, be required to display licence plates, and have third party insurance?

Is there any evidence of an actual impact from illegal ebikes that nessecites such a harsh and expensive response? Yes ideally their should be better regulation, but i don't think mass criminalising people, including ones that might not even be using an ebike, is something necessary.


The moral panic over e-scooters is the same, for something portrayed as such a danger, they have yet to kill someone who isn't riding one, which is remarkable for a relatively common, yet unregulated, mode of transportation

 

[jon0844]

I am sure I've read of at least one person having life-changing injuries from being hit by an e-scooter, possibly even killed. I'd agree that it's often the rider themselves injured, although surely we have a responsibility to try and reduce all accidents. That's why road designers should put a lot of effort into designing out accident hotspots, even if we could just sit back and say 'why bother? if they crash, it's their own fault'.

This extrapolates to those who think health and safety rules have gone too far, and that 'back in the day' they didn't die when no such rules existed. That's called survivorship bias, given the ones that did get killed aren't around to say 'Well, actually...'.

 

[renegademaster]

I am sure I've read of at least one person having life-changing injuries from being hit by an e-scooter,

To put that into context:

Between 2019-2023

12 fatalities and 690 serious injuries caused by pedal cyclists colliding with pedestrians

99 fatalities and 930 serious injuries caused by buses colliding with pedestrians


And all these are dwarfed by the >1000 killed by motor vehicles.

Source:

Reported road casualties in Great Britain: pedestrian factsheet, 2023

www.gov.uk

Criminalising cyclists, ebike and e-scooter users isn't going to make a substantive difference if your goal is to make pedestrians safer. The huge resources trying to enforce licensing on all commercial cycle users as @BlueLeanie suggested will take resources from policing cars.


On a positive note, the above linked report does highlight that pedestrian fatalities and injuries have been on a consistent decline year by year for the last decade and so, and the rise of the delivery apps haven't seemed to reverse that trend

 

[jon0844]

So we don't worry about modern technology that allows a humble bike to be able to do 30, 40, 50mph or more - or the e-scooters also able to do ridiculous speeds, and ridden by 'roadmen' all in black?

I don't want to ban bikes (or I'd have to get a second car) but our cycling infrastructure is not geared (sic) to cope with these things. I believe an e-scooter or 'proper' e-bike (more an e-motorcycle) needs to be on a road or dedicated cycle lanes, NOT shared pavements.

Cars kill more people than people are murdered, but I nobody suggests ignoring murder. And, no, I'm not saying someone on an illegal e-bike is intending to murder anyone, but if you continue to allow these things to proliferate then the dangers increase.

 

[styles]

Presumably if privately-owned e-scooters are to be legalised (which the Transport Secretary has said the current government intends to), this is an opportunity to review things like the requirement for e-bikes to only be electric-assist.

I'm probably a bit optimistic thinking the government might try and simplify legislation though aren't I.

I too would agree with increasing the limit to 20mph. I base this on my one experience on an e-scooters (trial scheme), where, unlike with a bicycle, you can't pedal to go faster and keep up with traffic. Cities like London, where bicycles and scooters are ideal, are bad enough with road user aggression, without reducing their speeds by 25%. Well realistically a lot of drivers are doing closer to 30 in 20 areas so you're potentially doing half their speed, but that's another issue. I also suspect that in doing so, the market for non-road-legal bikes/scooters/conversion kits would drop as most people would see 20mph road legal options as more than sufficient. 20mph is after all a decent pace for a push bike or e-scooter.

I wouldn't add any licensing, insurance, etc burdens. Pretty much every country which has tried this for bicycles has eventually ditched it after realising it costs a fortune and doesn't delivery noticeable benefits. The countries which do retain mandatory registration schemes (e.g. Japan on the owner, Denmark on the retailer) do so in the name of theft prevention, and don't require reg plates to be visible etc. Helmets there is conflicting evidence for, with some studies showing risk compensation, both from the rider and from other road users, may increase the likelihood of getting into a collision, while the evidence does support the idea that they reduce the impact of collisions, albeit not in collisions with larger motor vehicles like newer cars. I personally wear a helmet while cycling almost all the time, but if I'm popping down to London I'm not carrying a helmet with me just for a handful of short Santander cycle trips.

 

[Magdalia]

I come late to this discussion (blame tariffs for that). I have been riding a legally compliant ebike for almost 4 years now.

The 15.5 mph/25 kph maximum speed for electrical assistance should stay, for various reasons:

• many ebikes are manufactured for the whole of the European market, or use motors manufactured for the whole of the European market, varying our rules from theirs will increase the cost of new ebikes in the UK
• impact is proportional to square of speed so force of impact at 20 mph is 67% higher than at 15.5 mph
• an ebike weighs a lot more than a normal pedal cycle because of the weight of the motor and battery
• together these are particularly significant for collisions with pedestrians
• the cycle helmet crash standard is assessed at 12 mph, that ought to be at 15.5 mph but is a long way from 20 mph

Private use should not have legal requirements for helmets or insurance, but these should be essential for anyone riding an ebike as part of their employment.

 

[styles]

I come late to this discussion (blame tariffs for that). I have been riding a legally compliant ebike for almost 4 years now.

The 15.5 mph/25 kph maximum speed for electrical assistance should stay, for various reasons:

• many ebikes are manufactured for the whole of the European market, or use motors manufactured for the whole of the European market, varying our rules from theirs will increase the cost of new ebikes in the UK

I believe this will be the main reason we won't move from 15.5mph. It'll take us out of step with

• impact is proportional to square of speed so force of impact at 20 mph is 67% higher than at 15.5 mph
• an ebike weighs a lot more than a normal pedal cycle because of the weight of the motor and battery
• together these are particularly significant for collisions with pedestrians

While true, the number of pedestrians killed by all cyclists in the last full year of data, was 4. I'm not going to downplay 4 deaths, but as with everything, a balance has to be struck. It is entirely possible that some of these deaths were not even e-bike involved. Before e-bikes became popular, it was around 2 per year annualised. That's before we even consider the population increase, increase in motor vehicle traffic, etc. I'm unconvinced that e-bikes have led to a drastic increase in pedestrian fatalities, and I'm unconvinced that the electric assist being upped to 20mph would make much difference either. When you drill into the specific examples it turns out it's people running red lights, cycling on bikes which don't have brakes, or are misclassified illegal ebikes (which are technically mopeds).

• the cycle helmet crash standard is assessed at 12 mph, that ought to be at 15.5 mph but is a long way from 20 mph

Potentially, yeah. With MIPS and modern material design, cycling helmets are excellent even at relatively high speeds. All this would really do though is change colour on some gold/silver/bronze safety rating - after all, if manufacturers could reasonably make cycling helmets safer, they would; they invest huge amounts of money into R&D to do this already.

Private use should not have legal requirements for helmets or insurance, but these should be essential for anyone riding an ebike as part of their employment.

Why would using a bicycle for work change whether the rider should wear a helmet? Helmets are for their riders' own safety, so their category of use shouldn't really affect things imo.

If you're using any mode of transport for work, including walking, you should consider third-party liability insurance. I don't believe it should be a legal requirement though. It's on you if you mess up a customer's order and have to reimburse them. This is different for motor vehicles, sure, but that's because motor vehicles weigh often 150x more than a bicycle, and have 0-60mph rates which are through the roof, with top speeds of well over 100mph.

 

[Bletchleyite]

Why would using a bicycle for work change whether the rider should wear a helmet? Helmets are for their riders' own safety, so their category of use shouldn't really affect things imo.

It's likely an employer would enforce that themselves in any case. That the likes of the Roo don't actually act like a reasonable employer would is something that really is for other legislation. We really do need to sort the "gig economy" issue out.