e-bike - Google News

Thursday, June 18, 2009

Sample action letter to send [NEW AND REVISED]


SEE: http://onteba.blogspot.com/2009/10/ontario-legalizes-ebikes.html

When you respond to the MTO appeal for clear information as they formulate eBike regulations, please copy the text below and paste it here. If you'd like to ensure your municipal and provincial politicians are up to speed on issues about eBike regulation, you can also send them this letter (get their address):

[copy and paste into the MTO response form]

To Whom it May Concern:
I am writing to you today to respond to the MTO's recent request for public input about e-bikes.

You have asked for responses to specific questions, and comments about concerns that MTO recently raised in a presentation to a selected group.

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

(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."

The CEVEQ report says 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 more recent CCMTA report 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." Why is a bike’s ease or difficulty to carry or put on the car roof relevant to its roadworthiness?

(c) "There is too much weight in relation to its maximum speed; the weight noticeably increases acceleration when you go down hills."

This is, in fact, two separate statements in the CEVEQ study and MTO has put them together.

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.

(d) "Weight, not the motor’s maximum power assist speed, was the characteristic cited most often as a reason for feeling insecure."

The CEVEQ report states: "The study showed that cyclists did not view the e-bikes as a safety risk." Overall, bike weight was a concern of 21 people in the test. More than half of them were concerned about the weight of their conventional bicycle.

Here are some other excerpts from the CEVEC study:

- 97 per cent of the Ontario testers thought EPBs and EABs were as safe as 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 as 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).

As to the MTO specific questions,

1. I think that Ontario's status quo addresses almost all of my concerns; I would not oppose prohibiting tampering with an eBike or eScooter in order to increase its speed. That is a road safety issue and I agree with keeping roads safe. MTO seems to misunderstand that the CCMTA would somehow prohibit eScooters. This is not true. The CCMTA report (http://www.ccmta.ca/english/pdf/power_assisted_cycles.pdf) clearly states that "Jurisdictional regulations should be consistent with federal statutes concerning power assisted bicycles," and eScooters comply with federal regulations on PABs.

2. A great many of the 'scooter-type' eBikes on the road would not meet Low Speed Motorcycle standards; they have been manufactured in good faith to meet international and federal "Power Assisted Bicycle" standards, which are different. Requiring eScooters to meet LSM standards is not practical and would effectively remove them from the marketplace since Ontario would be the only place in the world with such standards and put Ontario at odds with the federal standards already adopted elsewhere in Canada. Furthermore, their "appearance" like gas scooters is only skin deep. Their lightweight outer shell does make them a stylish consumer option for eBike purchasers. It doesn't make them a motorcycle.

3. Are stakeholder concerns related to weight/size/braking of some e-bikes, particularly scooter-style ones, justified? No. The CCMTA and CEVEQ studies are easily misinterpreted about braking. Although it was a dominant theme when people talked about safety, the vast majority did not think safety was an issue at all. And the safety issues discussed were in comparison with conventional bicycles. Overall, most people thought e-bikes were safer than conventional bikes.

I would also like to point out that eScooters have wider tires that are considerably safer to use when riding near Toronto's streetcar tracks. I would estimate that hundreds of conventional cyclists have dangerous unreported accidents every year because of the streetcar tracks.

Every eScooter rider I have ever talked to feels safer on the road than they have on a bicycle because of the wider tires, lower centre of gravity, 32 km/h maximum speed, balanced and safe shopping bag stowage, and the mandatory helmet and in-built safety devices such as horn, signal and brake lights.

4. The CEVEC report clearly states that e-bikes are not for everybody, and will remain a smaller proportion of the two-wheeled market. As for the proportion of eScooters now on the road in Ontario, I would guess they are becoming the majority. They have been a popular consumer style choice. They are simply that: a style choice. They should not be banned simply because they "resemble" something else, or are considered unattractive to some people.

5. I am not an eBike retailer, but I can tell you that there was a purchase expectation that Ontario's regulation of eBikes would harmonize with all our neighbouring provinces and with federal law and recommendation.

6. There is a lot of published research about eBikes that supports not only their safety but that validates their successful integration into the cycling community.

This report: (http://www.scribd.com/doc/1960031/Electric-Bike-Use-in-China-and-Their-Impacts-on-the) is an academic paper that, after an exhaustive study of safety, pollution and conventional cycle complaints, summarizes: "Cities should embrace e-bikes." The study was commissioned by two city governments that had, based on misinformation and misunderstanding, initially planned to ban eBikes.

The original federal Motor Vehicle Safety Act that allowed eBikes on Canadian roads (http://gazette.gc.ca/archives/p2/2001/2001-04-11/html/sor-dors117-eng.html) found, among many positive benefits of eBikes, that eBike riders were more likely to obey stop signs. No subsequent research has shown anything different.

A presentation by the European Cyclists Federation refutes the Toronto Cyclists Union assertion that bicycles are noisy. "Bicycles are silent," the ECU told the EU in this presentation: http://ec.europa.eu/transport/strategies/doc/2009_future_of_transport/contributions/20090326_ecf.pdf

The Insurance Bureau of British Columbia's annual reports of bicycle collisions that result in injury or death have never indicated the design/weight/handling of eScooters or eBikes to be a safety factor. EBikes have been fully street-legal in British Columbia since 2003 under regulations almost exactly like Ontario's status quo. Here is the most recent (2006) report. http://www.icbc.com/cs/Satellite?blobcol=urldata&blobheader=application%2Fpdf&blobheadername1=Content-Disposition&blobheadervalue1=filename%3D%22collisions-2006.pdf%22&blobkey=id&blobtable=MungoBlobs&blobwhere=1233967816630&ssbinary=true

The CCMTA report cited by MTO is very supportive of eScooter and eBike use: http://www.ccmta.ca/english/pdf/power_assisted_cycles.pdf

7. Future design innovations you should be aware of include:

*new and affordable metal alloys and battery technologies will continue to make e-bikes lighter and more energy efficient. These changes are imminent in the marketplace;

*three-wheeled designs that allow larger storage capacity may become popular among urban people wishing to do shopping, and also with urban delivery services like pizza or flowers;

*three-wheeled designs with approved baby-seats are being tested; they are certainly more safe than those 'kiddy trailers' towed by conventional bicycles.

Thank you for reading my letter. I hope this helps you come to an informed decision that will lead to harmonizing Ontario's integration of eBikes into the mainstream bicycle community, thus matching how Power Assisted Bicycles have become part of the everyday bicycle communities in B. C., Alberta, Saskatchewan, Manitoba, Quebec, New Brunswick and several U.S. States.

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1 comment:

Anonymous said...

Thanks so much for this site!!!

Today I contacted my local MPP and asked his help in convincing Jim Bradley (the Minister of MPO) that he needs to come down hard on the loose cannons in his department who've hijacked Ontario's Ebike process. They need a trip out behind the woodshed for a well deserved thrashing.

These clowns are destroying the Ebike in Ontario and all Ontarians will be the poorer for it. I've worked over 20 years in government and rarely have I seen such arrogant and un-professional Empire Building within the bureaucracy.

I'll definitely be sending in a copy of your excellent letter.

Keep up the good work!

PS: can you enable pasting text into this comment window ... that would make composing messages easier.