My take on this... Its LOOOONG.
Basically boils down to:
Enforcement is unjust and inaccurate (specify useless tools to measure)
Environmental issues not considered
Perverse Logic (ie. will encourage more cyclists (wont - compliant bikes are more expensive), so more cyclists means more visibility, more visibility is safer. Unfortunatly the opposite is also true!)
Social / Economical issues not considered
Encourages cyclists to use PABC's on shared paths (stupid and dangerous) as a way of reducing accidents.
Poor understanding of engineering concepts and bad interpretation of statistics (and some pretty old data that is most likely out of date)
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Executive Summary:
The proposed legislation raises a number of questions that remain unanswered from the previous ADR definitions.
Whilst most welcome the changes to legislation (and agree that there should be a requirement for pedalling to be neccesary to get assistance), enforcement is plagued with vaugearities, due to the measuring apparatus having insufficient granularity (and hence accuracy), and the requirement for a pedal assistance potentially adding power (the use of a testing mode not requiring pedalling, or a calibrated human analogue), along with the ignorance of the requirement of a bicycle to freewheel (observed riding the vehicle without pedalling) on the flat or down hills to be efficient, and also the requirement for assistance to drop off once 25Kph is reached (would definitly require a human analogue on a calibrated dyno to prove).
It is obvious that the RTA and the police force need to consider the accuracy of enforcement in a fair manner - or risk numerous court battles to define these regulations furthur. The case of Matheson v Director of Public Prosecutions found in favour of the prosecution due to the fact that the defendant admitted to only using the pedals when the battery was flat (and it was possible to use without pedaling) - therefore propulsion was not auxilliary.
But if a person was convicted solely on the fact that they were observed riding without pedalling, and the bike met the power output requirements, the case would be dismissed.
The requirement to reduce assistance past 25Kph is contentious - the report admits that regardless of power reduction, the majority of target users would be able to exceed the 85 percentile speed of the Monash University study. This requirement adds uneccesary complication and expense.
The PABC has been historically a low-carbon-footprint vehicle, and alternative transport to cars - The expense of purchasing (or replacing an existing and now non-compliant) PABC will discourage their use furthur. Some of the suggested models are priced similarly to a cheap used car, or a brand new motorcycle - vehicles with much greater range but a bigger carbon footprint. Cynics could be forgiven in questioning the motives of the RTA, to encourage the use of vehicles on which fuel excise, registration and licensing is required.
The environmental impact of this legislation also needs to be considered - there are hundreds of non-compliant ebikes both in use and also awaiting sale in retailers - what will become of these? Will they join landfill and their toxic battery chemicals leach into the water table?
Or the social / economical implications - there are a number of retailers who suffered from the results of the case of Matheson v Director of Public Prosecutions - for example Ezyride in Newcastle, NSW closed their business, ascribing this as a consequence of the results of this case.
There are still a number of retailers who specialise in PABC's whose stock will become non-compliant as a result of changes to this definition - will they be compensated when they have to dispose of their non-compliant stock?
"The organisation Extra Energy calls these two systems ‘pedelecs’
or ‘e-bikes’ respectively and both types meet the European definition of a PAPC, detailed in
Appendix B. The tests conducted since 2001 on a variety of European PAPCs on the website
www.extranergy.com cover both systems."
This website is 'under construction' - makes it difficult to verify this statement without a published source.
"300 watts: This is the limit allowed in New Zealand. No safety analysis has been found to
justify this level of assistance.
Typical unassisted speed: 27.5 km/h."
What safety analysis has been found to justify the 250W level of assistance?
300W is what the 85 percentile of average cyclists produce based on a study by Monash University of 1162 cyclists in 5 days later in this report. (P13)
"500 watts: This is the limit allowed in Canada. Transport Canada’s Regulatory Impact
Statement says that ‘500 watts is a level that well-trained athletes can maintain for a short
period of time’3. The NSW Centre for Road Safety believes that 500 watts is far beyond a
sustainable power output for an average cyclist, therefore it would provide PAPCs with a
level of performance superior to a standard bicycle.
Typical unassisted speed: 33.0 km/h."
Belief is not fact, nor may it be presented as such without substantiation. The NSW centre for road safety needs to quantify what power output is a sustainable output for an average cyclist.
"This would open the Australian market to a volume of high quality PAPCs designed and manufactured for bigger markets and will facilitate the export of locally designed and manufactured products."
Extremely unlikely - this would require retooling and research & development, along with marketing and price competition in an established market. It would open the Australian market to a volume of high quality PABCs designed and manufactured for bigger markets and
stifle established manufacturers and resellers. Pure spin and rhetoric.
"In the scenario that a cyclist providing 300 watts unassisted on a road bike is given a similar bicycle
with 250 watt motor (that is not speed limited), the same effort from the cyclist would propel him
or her at 40.5 km/h. This is a 24.6% increase in speed over 32.5km/h and a 55% increase in kinetic
energy before considering the increased weight. A 75 kg rider travelling on a PAPC weighting 20
kg instead of a 10 kg road bicycle would carry a further 11.7% more energy. The increase in speed and weight would require an additional 15 watts to compensate for the greater friction, but this
small effect is not considered in this analysis."
These figures are correct in theory and in practice, and allow a cyclist to ride safely in traffic without becoming a nuisance to other traffic, and to reduce their likelyhood, to use motorcycle parlance, of "becoming road pizza". That is - to reduce their likelyhood of having a traffic fatality. This is a good thing, not bad.
"For enforcement purpose, measuring the power at the wheel is the simplest method as it can be
applied regardless of the power source and of the vehicle configuration. This methodology
provides a slight underestimation of the power at the motor because the power losses in the
drivetrain are not measured. Therefore if rear wheel power exceeds the limit, then the electric
motor power will also exceed the limit.
A chassis dynamometer designed to measure the power of motorcycles could be used initially, as
in an inquiry undertaken in Tasmania9. The same type of dynamometer is available in every State
and Territory across Australia10."
This is of
MAJOR CONCERN. The specified dyno has a resolution of 0.1KW, obviously unsuited to this purpose. The requirement for pedalling would mean that an otherwise compliant bike could potentially become non-compliant if an uncalibrated amount of assistance is added.
Depending on Dyno accuracy (which changes from dyno to dyno, and day to day) and rounding - (250W becomes 300W, or 200W - BIG DIFFERENCE!) the only possible way to measure this accuratly is with a dyno of great accuracy and better granularity (eg. 0.05 or 0.01kw) coupled with a known amount of assistance (a human analogue) or bypassing the pedal assitance function for testing purposes.
Enforcement is the most pertinent factor in this legislation and the RTA is only suggesting the use of an inaccurate measurement technique that results in false positives.
"During a discussion with a local PAPC manufacturer, it was suggested that the maximum current
output of the controller influences the possible peak power of the motor. In the case of a 36 volt
battery combined with a 25 Ampere controller, the theoretical peak power of the motor would
be 900 watts. It was estimated that the system could not sustain this power for more than 10
seconds."
The 900W peak theoretical power is dependent on battery technology, and assumes 100% conversion efficiency which is unlikely.
"
After one minute, the maximum speed of an upright rider would be 30.4km/h and would
subsequently come down to a slower speed of 25.4 km/h without the extra peak power. A cyclist
in racing position would, during the same time, go from 30.5km/h to 35.1 km/h, however this case
is of less interest as it doesn’t represent the typical user of a PAPC. Both scenarios using 900
watts during 10 seconds offer a smaller maximum speed.
In conclusion, the short speed burst created by a hypothetical peak power available at top speed
would result in a low acceleration for a limited time, within the 85th percentile speed of a cyclist. In
the case that a maximum assisted speed is required, the effect of peak power would be contained
within the limits of the maximum assisted speed."
But how would this affect enforcement? It must be based on continuous power over time, not peak instantaneous.
"Faster cyclists would also
benefit from motor assistance without a maximum assisted speed, although the relative benefit of
assistance decreases sharply with an increase in travelling speed. The safest option would be to
limit motor assistance to a certain speed above which the cyclist is providing all the motive power.
For this reason it is proposed to require a maximum assisted speed of 25 km/h combined with the
power restriction to 250 watts. The rider could add to this power in order to travel faster, but because power increases
with a cubic relation to speed, it is believed the majority of the target riders would not travel
faster than the 85th percentile speed as measured by Monash University."
So why limit the assistance to 25Kph then? A 'target user' would not travel faster than the 85 percentile, and anyone who
could (eg. serious road cyclists in a racing position) has far greater compenency and braking ability (due to lowered kinetic energy due to weight reductions) than the target user anyway.
"Conversion tools available on the Internet show there are about 15 to 17cc to 1
horsepower, and 1 horsepower is about 745.7W (see also Commonwealth National
Measures Regulations 1999, Schedule 11). Using this formula, 200W would be provided by
roughly 4cc. The lack of precise conversion factors clearly demonstrates the difficulty in
establishing the output power in watts for petrol motors. This makes compliance unenforceable. In any case, the examples vary from 750 to 2155W, and are indicative of most petrol powered motorised scooters available on the market, and well in excess of the
current 200W requirement. A model aeroplane motor at 7.5cc can also be considered for comparison purposes. Using
the above scenario the aeroplane motor would range from 328 to 374W (in excess of the
required 200W): model aeroplane motors are much smaller than those fitted to motorised
scooters."
HIGHLY, HIGHLY inaccurate. These are peak power figures at maximum RPM, which, for the longevity of the engine, and noise output, should not be used continuously.
There are numerous equations for determining engine power, capacity is of absolutly no use. Engine output is a function of Torque X RPM. More accuratly, Power = Torque X angular velocity. To convert angular velocity (radians per second) to rpm, - RPM/60 X 2 X Pi (radians in 360 degrees).
For example, a readily available 31cc 'whipper snipper' engine has a peak torque at 5000 rpm of 1nm, and peak power of 800W at 6000 rpm. A small engine would normally be used at peak torque (where it is running at its greatest efficiency).
Power (W) = Torque (nm) X (RPM/60 X 6.284)
Power = 1 X 5000/60 X 6.284
Power = 523W
By mapping the power curve of this engine (using the cubic equation HP=c+aX+bx2+cX3 where x is the rpm) (using Chris Barry's coefficients - see
www.boatdesign.net/Forums/attachmen...ne-torque-curves-engine-output-calculator.xls for more) it is possible to restrict this engine to 250W by limiting its maximum RPM to 2250 rpm (limiting it to 248.74W, and 1 nm). This is done by restricting exhaust or intake, or loading the engine so that it is not possible for its RPM to rise any furthur (as per the GOMO friction roller kits).