Friday, 26 May 2017

L1e-A Type Approval - Missed Opportunities

1 - L1e-A Type Approval - Missed Opportunities - Intro

The L1e-A class of vehicle is at at present described in European Directive 168/2013, at the moment there is no way of obtaining UK type approval for this vehicle. If you built a 15 mph 1000w ebike it would need to undergo the same inspection process as a Motor Bike.

But for now let us imagine that the DVSA had the resources to publish a list of requirements. If they followed the requirements set out in European Directive 168/2013, then the below list (Chapter 2) would be required, and uptake of the L1e-A vehicle class would be minimal. 

If we are to release to full environmental benefits of electrically assisted pedal cycles then we must allow a higher power rating under existing EAPC regulations, whilst maintaining current 15mph speed limit. 

If one has to tax and insure these higher powered, but low speed (15mph) vehicles what is the incentive in operating one? One may as-well opt for a "real" motor bike or a car.

In my various emails shared with the Department for Transport (Chapter 4) no reason for the current 250w limit has been given, the USA have a 750w limit which has been in use for over a decade. 

In short this could be a very useful, zero emission, transport solution. We need to clean up our air, we need to reduce our carbon emissions. 1000w 15mph EBikes and ETrikes could take over many of the jobs that Small Vans and Car currently do in our cities. 

Passengers . . .
. . . post. . . .
. . .  or freight.
Most of these heavier cycles are popular in the "low countries" such as Belgium and Holland. In the hilly UK, if these pedal powered vehicles are to be success then we will need a 1000w power limit on an assisting electric motor.  

2 - L1e-A Type Approval - Missed Opportunities - Requirements

L1e-A - Horn

You will not need am audible warning device. AKA a Horn.

L1e-A - Brakes


According to UNECE Reg. 78 unless the vehicle weighs less than 35kg. In which case normal bike brakes will be OK.

Rim widths must be kept under 45mm to avoid stopping distance requirements.

L1e-A - Endurance

Needs to be able to last for 5 years. Which bits this applies to I do not know, likley the frame I should think. 

L1e-A - Lights and Signals

A headlamp, a side reflectors, pedal reflectors. Headlights can be switched automatically or manually. No rear light is required.

This is rather silly. A rea light is one of the most important safety features on a bicycle. . . . the mind boggles.

L1e-A - Saddle

A normal bicycle saddle.

L1e-A - Tires

Normal bike tires provide loaded weight is below 150kg, and the tires are less than 67mm in width. This translates to 2.35" cycle tires being OK, which is pretty wide. 

L1e-A - Anti Tamper

The vehicle user should not be able to alter the vehicle speed above 15mph, with (i am guessing) an off road switch or similar.

L1e-A - Vehicle structure integrity

Must conform with EN 14764:2005. This is a bicycle standard realting to "City and trekking bicycles." So if you are converting a modern bike of the correct type then it should comply. However, this standard does not apply to:

"It does not apply to mountain bicycles and racing bicycles, tradesman's delivery bicycles, recumbent bicycles, tandems and bicycles designed and equipped for use in sanctioned competitive events."

L1e-A -Passenger handholds and footrests

These are not required. However this would suggest passengers are allowed. . . 

L1e-A - Registration Plate / Number Plate

10cm by 17,5cm space is required for mounting. This is annoying. This is large un-aerodynamic thing to fit on to a bicycle. 

L1e-A - Kick Stand

Yes you need one of these. A kick stand, or two foot stand for example. 

L1e-A - Propulsion Unit performance

This is a little complex, and will depend on the type of system. If a pedal assistance system then there are standards to be met (EN 15194:2009 &  UNECE Reg. No 8)

L1e-A -Electric energy consumption and electric range

There are no minimum range requirements. 

3 - L1e-A Type Approval - Missed Opportunities - - Conclusions

One of the great joys of owning a ebike is the lack of legislative burdens. No tax, no insurance, no requirement to wear a helmet. . . . 

The L1e - A category has the potential to revolutionise inner city transport if implemented correctly and sensitively. But if regulators are too heavy handed this form of vehicle will be relegated to an obscure and underutilized form of transport. 

4 - Type Approval Requirements L1e-A - Letters to DfT

I have had various contacts with the the Department for Transport. I would rather see this L1e-A bracket included under EAPC regulations.

Letter 1

An initial enquiry, brought boiler plate response. So . . . my response.


I think in the days before the world wide web, the response may well have been a useful one. But it is repetition of information that I have already read, and already have access to. It is all very well to choose 250 watts as a maximum power rating, but I fear this figure has been chosen at random with no true understanding how an electric motor works.

How will this be enforced? – We have a enforcement system that measures speed, not power.


Practicality? – Would you place a power limit on a Tractor?


Worthy Contribution? – A moderately fit rider can produce 800w power when cycling. 250w as an addition is rather small.


I summary I am trying to investigate why this 250w figure has been chosen. I would like to think there was some science behind it somewhere. . . . but I have a strong suspicion it was plucked from the air.


DfT response to Enquiry on why current limit is 250w.

Directive 2002/24 made type approval compulsory for all two wheeled motor vehicles,  except powered cycles not exceeding 250 watts. 
Unfortunately we have no detailed information on why that threshold was chosen. It may  have come from a prior threshold in an EU country where such cycles were common eg  Netherlands.

Letter 2 - Higher Power for Low Speed EBikes 

My Letter - Enquiring About Power Increase

Now that we are leaving the EU could we open a dialog on how best to increase max allowable power on pedal assisted EVs? To be clear 15mph speed limit would be maintained, with increased assistance level and torque.



Since our last communication we have heard that diesels will likely be banned in cities, and I think it is likely that electrical assisted vehicles can fill this gap.



With the price of electric cars and vans being inhibitive for most, I think now is the time to investigate this possible review of the EAPC regulations. Here are some links to some vehciles that would benefit from a change to the regulations: 




For Passengers



http://pedalistcycles.com/

https://blogvelocity.wordpress.com/2016/10/14/excellent-piece-of-cargo-bike/



For Cargo



http://vrachtfiets.nl/

https://twitter.com/fahrradwien/status/800967612108783616?s=09



Surely this is worth looking at? We have an air quality and emissions mountain to climb in the next decade and this can only help. . . .

Dft Response to Increasing 

Thank you for your e-mail of 27 April concerning electrically assisted pedal  cycles (EAPCs). I have been asked to respond as I work in the Department  for Transport’s cycle policy team and lead on EAPCs.

As we are currently in the pre-election period, known as purdah, new policy  decisions cannot be taken until after 8 June when a new Government will  have been elected.

You may be aware that prior to the beginning of the purdah period detailed  guidance on compliance issues affecting certain EAPCs was published on the  Department for Transport’s website. For ease of reference here is a link to  the guidance.

My response to This

Thank you very much for you informative response. I had seen a draft of your linked document last year, I am worried that if these slow, low powered cycles are grouped with motor vehicles that the added administrative burdens will prevent their uptake.



I have recently read that there is a directive 168/2013 that introduces the category L1e-A for type approval. That is a 15mph top speed but with a 1000w power allowance.



This is exactly the type of bicycle I think that would prove useful for passenger and load carrying, and would provide a real alternative to cars and vans. Especially in hilly areas, were the current 250w allowance does not contribute meaningfully.



These types of cycle would also allow individuals and businesses to opt for zero emissions transport at a fraction of the cost of an electric car. This would accelerate the inner city air quality improvements required of the UK, whilst adding to the fitness and wellbeing of those using the cycles.



I believe that the DfT are updating type approval regulations at present, I would ask that the L1e-A category is merged with the EAPC regulations. I am of the opinion that attempts to classify these cycles as motor vehicles would severely restrict there up take, and thus limit the myriad of positive effects that they would bring for those using them, and air quality.



Finally, it is very difficult to enforce a system based on power ratings, at present our enforcement system favours speed as an enforcement mechanism, which most police can measure easily. If a bicycle is limited to 15mph, then there is very little point in having any more than 1000w power, any more and it is surplus to requirements. 

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