I am writing to express my…

I am writing to express my concerns about the proposed e-bike regulations and to propose an alternative approach.

Passing is one concern. The motor on e-bikes currently has a top speed of 32 km/h whereas more than 90% of people on pedal cycles maintain speeds of between 10 and 25 km/h on flat pavement. Because of this speed differential, e-bikes pass pedal cycles with great frequency. And this is a problem when the person on an e-bike leaves less than a meter of space between their vehicle and the pedal cycles they overtake: pedal cyclists can’t hear them coming and are surprised and frightened when it happens. Typical involuntary responses to being passed too close include a momentary loss of control of steering, which can end in a collision or fall.

Collision severity is another concern. The severity of the injuries in a collision is closely related to the speed and weight of vehicles involved. When one of the heavier e-bikes collides with a pedal cycle, particularly if the e-bike is going 32 km/h, there is potential for serious injury. Vehicles with significant speed and weight differentials should be separated.

To reduce the risks of unsafe passing and severe collisions involving vulnerable road users, I suggest the following approach:

A) Create one class of e-bikes whose motor ceases to assist at speeds above 24 km/h and whose weight is limited to a maximum of 55 kg. Because this class of e-bikes would have speeds and weights comparable to pedal cycles, and could therefore safely share lanes with them, they would be categorized as power assisted bicycles and could be operated by anyone 14 years of age and over.

B) Create a second class of e-bikes whose motor ceases to assist at speeds above 45 km/h and whose weight is above 55 km/h and categorize these as motor vehicles. As motor vehicles, operators would be required to operate outside of bike lanes and to abide by the safe passing law. People using these vehicles would have to be at least 16 years of age, licensed and insured.

E-bike regulations in most US states are similar to the above and even they would be safer and preferable to what is currently proposed for Ontario.