Comment
Thank you for the opportunity to submit feedback on this process.
Generally, the three category framework is mostly adequate, but there is some nuance that could be added. With respect to Type 1: Throttle should be a factor of differentiation, even when weight, max speed, wheel size and power remain the same. Perhaps Type 1 could be subdivided, Into 1.a and 1.b, with mode of assist being the key difference. Pedal assist drives are more familiar, as motor engagement happens only as legs move, which is consistent with bicycling, whereas a twist grip can be applied inadvertently apart from the movement of the legs, so the potential for rider error increase.
The distinctions between Type 2 and Type 3 are clear enough. Although it’s a little unclear about how Type 3 will be governed, and what the implications of LSM being silent on electric drive is exactly.
Submitted June 12, 2021 5:44 PM
Comment on
Power-Assisted Bicycle (E-Bike) Redefinition
ERO number
019-3676
Comment ID
55024
Commenting on behalf of
Comment status