To Whom It May Concern, We…

ERO number


Comment ID


Commenting on behalf of

Green Street

Comment status

Comment approved More about comment statuses


To Whom It May Concern,

We own and operate a small bike shop in Peterborough, Ontario, and sell primarily electric bicycles and scooters. We are pleased to see a more inclusive and detailed definition of electric bicycles being put forth. However, as business owners, and also as regular e-bike users, we are quite concerned by the changes and amendments being proposed by Transport Canada in the definition of ‘electric mopeds’ and ‘motorcycle style e-bikes’.

First, these changes would have significant implications for our business. What you deem ‘electric mopeds’ or ‘motorcycle style e-bikes’ represent a massive percentage of our annual income. Indeed they are the cornerstone on which we have built our livelihood for the last thirteen years. The imposition of M class licensing on these devices could, in a single stroke, completely erase a huge portion of our business. Not only would it drastically impact sales of new units, but it will also affect our repair shop. Thousands of potential buyers will no longer have the option to purchase an e-bike for use on the road. Thousands that already own one will not bother bringing it in for repair. As small business owners, we are very afraid that your proposed changes could have catastrophic consequences.

In thirteen years of operation, we have seen first hand the wide range of people that turn to e-bikes as their preferred choice of transportation. Many look to it as a more environmental alternative to gas-powered vehicles. We have seen countless people go from a car-centric lifestyle to an electric-powered one. This can only serve to lessen our overall dependence on fossil fuels in Canada.

Some people choose e-bikes as a cheaper form of transportation. For many of our customers, cars are not a financial option. An e-bike allows them independence when commuting and going about their daily lives. They can get a load of groceries, go to the doctor and visit loved ones in the span of a single day out instead of in the span of a week’s worth of trips on public transportation. For many people in financially vulnerable positions, this is a life-changing and life-saving piece of equipment. 

Just one example would be our long time customer who has been able to take on multiple paper routes because of his e-bike. He comes from generational poverty and traditional employment was not an option. He rides his electric scooter every week of the year and is, therefore, able to put food on his table with the money he earns delivering papers. An M class license would not be possible for him so you would therefore be obliterating his primary source of income. Social assistance would be his only option thus putting greater strain on the already vastly overwhelmed welfare system in Peterborough.

The question may be asked, why would people not just turn to the electric bicycle as an alternative to the ‘moped’ or ‘motorcycle style’ e-bike. There are several reasons we can foresee. One is physical. Electric bicycles, although generally easier on the body than a regular bicycle, still requires some degree of physicality. Many people choose a moped-style because it suits their physical needs. The larger seat is easier on the back for those with injury or degenerative conditions. Resting their feet on a platform rather than rotating with pedals is more accessible to those with limitations in their knees and lower joints. Seniors in particular often find them the more feasible option. Stats Canada tells us that Peterborough’s population has the highest ratio of seniors of any city in Canada and we see this proven in our clientele. We have known many seniors to find freedom with their e-bikes. They can get out in the fresh air and maintain independence longer.

There is also the matter of price. Electric bicycles often tend to be on the higher end of the cost scale which is prohibitive for those on a fixed income. There are cheaper options of course but those do not carry the same capacity to tackle large hills and more treacherous terrain such as we often have in Canada. Peterborough, in particular, is known for its many large hills and our customers must always take that into account when choosing the unit that works best for them. There is just a wider selection of moderately priced electric ‘mopeds’ and ‘motorcycle style e-bikes’ that can take on rougher topography. Our friend with the paper routes, for example, would not be able to work as many routes as he can without the ability to climb the hills with his e-bike. He also rides all winter long and the heavier duty tires on his ‘moped’ make that possible and safer for him to do.

We understand that concerns have been raised regarding the safety of ‘electric mopeds’ and ‘motorcycle style e-bikes’ on the roads. Especially with them sharing lanes with cyclists or pedestrians. That being said, all e-bikes come equipped with a full set of safety equipment including lights, horn, brakes, and are required to ride to the right of car traffic. And there is already a speed limit set on electric bikes of 32 km/h. This is only slightly faster than the average speed of a person on a regular bicycle. Any e-biker will also tell you that they have been passed many times by folks on high-end road bicycles. 

Of course, we have seen people pushing the envelope with speed with many pulling the governor. To our minds, this is a law enforcement issue. Just as cars are ticketed for breaking speed limits so too should e-bikers. We do not think it is fair to hobble thousands of responsible citizens who rely on their e-bikes because a few people are breaking a law that is already in place.

We hope that you will take our concerns and the concerns of e-bikers all over Canada into account with making your decisions. 

Thank you for your time in reading this letter and we will be following the progression of this issue with great attention.

Supporting documents