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Thursday, June 25, 2009

MTO presentation uses erroneous eBike information


Ontario's Ministry of Transportation recently held a consultation meeting (June 16) at which it presented a slide show to invited participants, outlining what it perceives as discussion points and safety concerns about eBikes.

The slide show clearly put the onus on the eBike community to demonstrate to Queen's Park bureaucrats why this widely-accepted and adopted modern technology should be on Ontario's streets.

MTO's presentation puts forward for analysis, discussion and debate several statements ("concerns") about eBikes, many of which are not supported by any evidence, and some of which are contradicted by the very documents MTO is using to support the concerns.

For example, the MTO slide show includes a table comparing eBike regulations across the country. However, the table contains errors -- some obvious and some subtle -- about eBike rules in other places. (View larger image.)
  • The table shows British Columbia as strictly allowing only Pedal-Assist bicycles (P), but in fact B.C. allows both Pedal Assist and Throttle styles (B)... which they call MACs. B.C. is one of the most successful examples of how to integrate eBikes into the community.
  • The table shows Alberta as having a weight restriction on eBikes. Technically true on June 16th, this restriction is being removed July 1, 2009.
  • The table shows that the 2002 CCMTA report (Canadian Council of Motor Transport Administrators) which is widely cited by the MTO presentation, recommends "Pedal-assist only" but that is untrue. CCMTA's "Best Practices" report would allow Both (B) Pedal-assist and Throttle-only eBikes.
  • The slide show states that eScooter-style bikes would "likely ONLY be" permitted under Ontario status quo regulations; however the CCMTA report clearly states "Jurisdictional regulations should be consistent with federal statutes concerning power assisted bicycles." eScooters sold in Canada comply fully with federal PAB regulations, and therefore eScooters would also be allowed under the CCMTA best practices.

Documents contradict

There are other inconsistencies in the MTO presentation.

For example, the Ministry lists "absence of standards/requirements for e-bike electrical components" as one of its concerns about eBikes.

However, on slide 8 of the MTO presentation, the government agency asserts that the national advisory body (CCMTA) had already established "Electrical Wiring Reqt's" in its 2002 recommendations. Three pages later on slide 11, the MTO contradicts itself by claiming that the CCMTA has no such standards.

Accentuate the negative?

The presentation also cites selected excerpts from the 2000 CEVEQ study that the federal government used in creating its Power Assisted Bicycle regulations. The CEVEQ study, which road-tested eBikes for 25,205 km, closely subdivided eBikes into two categories:

  • EABs, which we now call pedalec or bicycles that have an accessory motor to assist a pedalist
  • EPBs, which require no pedaling and now includes eScooters.
The MTO presentation focused on excerpts that suggest that EPBs (eScooters) are somehow less safe than other eBikes. Findings from the CEVEQ study that support eBike use or address the concerns raised by MTO were not included in the list of selected excerpts, especially the summary that states:

"The findings demonstrated that the two e-bike systems – electrically propelled and electrically assisted – were equally safe."

These [positive] selected excerpts were omitted by MTO:
  • 97 per cent of the Ontario testers thought EPBs and EABs were as safe or safer than conventional bicycles. In CEVEQ's words: Most of the cyclists felt that e-bikes, whether assisted or self-propelled, were as safe and sometimes even safer than conventional bicycles.
  • In addition, users also noted that e-bikes encourage users to obey the Highway Safety Code more strictly (for example, they are more likely to stop at mandatory stops)
  • In general, respondents were highly satisfied with the user-friendliness, braking and reliability of the e-bikes, whether they were EPBs or EABs.
  • Sixty-four percent of all participants said they would use an e-bike to travel to work; 65 percent of those who usually travel to work by car said they would opt for the e-bike; and 71 percent of conventional bicycle enthusiasts expressed interest in using e-bikes to get to work.
  • E-bikes can reduce pollution and congestion in urban centres
  • E-bikes make it easier to stop and start frequently in city traffic
  • Greater provision should be made for e-bikes in city traffic (lack of bicycle paths, pavement in poor repair and lack of services).

Selected selected excerpts

The Ministry's list of selected excerpts from the 2000 study used by the federal government to draft the Power Assisted Bicycle regulations includes:

(a) "The cyclists considered brake reliability and performance to be the most important safety components on both electric bicycles and conventional bicycles, although they wanted to see some improvement in these areas." What the MTO doesn't mention is that 85 per cent of the testers had no safety concerns about brakes, and that brake concerns -- actually ranked third on the list of concerns -- were mentioned far more frequently by conventional cyclists than by eBike riders. Statistically, fewer than ten of the 369 testers made this observation.

Also, the 2002 CCMTA report favoured by MTO clearly defines a braking standard for eBikes and eScooters: "A motor assisted cycle must be equipped with brakes on all wheels or axles. The braking system must be capable of bringing the motor assisted cycle, loaded to its total capacity and traveling at a speed of 30 km/hr., to a total standstill within 9 m from the point at which the brakes were applied."

(b) "An e-bike weighs between 27 and 35 kg, which makes it difficult to carry or set in motion from a stationary position." In fact, what the riders were concerned about was: "It is difficult to lift the bike onto the sidewalk, place it on the roof of a car or position it on a bike rack." How difficult it is to carry or put on the car roof is irrelevant to an eBike's usefulness as roadworthy commuter transportation. Clearly if this is a serious issue, Ontario should ban bicycles built for two, recumbents and horses.

(c) "There is too much weight in relation to its maximum speed; The weight noticeably increases acceleration when you go down hills." These are, in fact, two separate statements in the CEVEQ study and MTO has put them together as if they were connected.
  1. The "maximum speed" in question was the then-legal limit of 24 km/h used in the eBike road test. All the users said that if the allowable speed were increase to approx 30 km/h, weight would not be a complaint. eBikes are now allowed to go 32 km/h.
  2. The weight and modern motor restriction of 32 km/h will now actually prevent eScooters from the dangerous speeds reached by pedal bicycles traveling down a steep hill.
  3. The EU set a new eBike weight restriction of 40kg in April 2009, about two months before the MTO presentation. It will apply to new bikes sold, which means new models coming onto the world market will be lighter.
(d) "Weight, not the motor’s maximum power assist speed, was the characteristic cited most often as a reason for feeling insecure." Also in the CEVEQ report: "The study showed that cyclists did not view the e-bikes as a safety risk. Cyclists in both cases, therefore, felt they had firm control of their bicycles and did not feel any particular concern for their safety." Overall, weight was a concern of 26 people in the eBike test. An equal proportion of conventional cyclists in the test were concerned about the weight of their conventional bicycle. Also, (see above) the EU now has a weight restriction that manufacturers will have to meet, meaning new PABs coming onto the world market will be lighter.

Limited options

In its call for public comment, MTO has suggested it will adopt one of three possible strategies: regulations suggested by the CCMTA, keep Ontario's status quo, or adopt European Union policies.

All other Canadian provinces with established regulations governing eBikes and eScooters have followed the CCMTA "best practises" document's chief recommendation: "Jurisdictional regulations should be consistent with federal statutes concerning power assisted bicycles."

And the CEVEQ study quoted so often by MTO clearly recommends:

"E-bikes admittedly have little appeal for competitive cyclists or mountain bike enthusiasts. However, they are a feasible mode of transportation for commuting to work or travelling short distances. As with conventional bicycles, the more varied the choice of e-bikes, the greater the number of consumers who will find a product that meets their needs.


Warren Christiani said...

To the ONTEBA owner:

Lots of good information on this web site but I have been unable to figure out who you are or how to get in contact with you.

Please send me an e-mail warren@durhamebikeassociation.org

Warren Christiani
President, Durham E-Bike Association

Anonymous said...

I don't know who they are either but they are certainly my new best friends.