Call to Arms all Australians Concerning MB Regulation

will-start
Like I said before , I am out of this discusion, I have said what I think. And in no way do I mention protestations.

I mention "art", "engineering" on bikes with internal combustion engines is a logical thing to do and to back that up then the MB Day idea is just incase to have a show of numbers of a synchronized global gathering of MB enthusiaists, nothing more and nothing less due to the fact the draft proposal has based some of it's recomendations to be in line with other countires.
Well, so can we, be in "line with other countries" if need be.

It's also quite obvious the RTA might well think the same as they have made no mention of internal combustion engines on bikes, yet. They seem more focused on electric. So what exactly are you proposing to protest about ?
If anything, crunch the carbon footprint cos that seems to be a "hot item" on the gov's agenda lately. Electric Bike ( including manufacture and life of it's rechargable batteries) Vs a restored hard rubbish re-build with a HT.

Unless you can clarify by showing a copy and paste section of what you have read and what is your concerns to react in "protest", then harp all ya like and form your own "protest day", not on my MB Day August 15th's idea thank you very much !
And if the MB Day idea does not get off the ground, I could not care less anyway
 
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So what exactly are you proposing to protest about ?

Fair point, being 31 pages long and full of tech speak,
its takes a while to find the bits that wipe petrol motors
off the road permanantly.

But here's the section that does it, by comparing 2 strokes
to electric hub motors.

By this same reasoning used in the document,
we should get rid of all Petrol cars and replace them with electric models
as they make less noise and pollution.
Its obvious the electric bike companies will have had a big input,
as it's listed all their different models in appendix C but nothing
of petrol engine models are shown...


Cut and PASTE from Page 17 and 18:

The benefits of allowing electric motors include less noise, no exhaust emissions (common
knowledge), a greater ability to identify the power of the motor, the ability to modify the
output power of the motor without fitting a governor, and generally lower speed capability.
However, petrol motors produce considerably more noise (and even more with a lesser
exhaust system), more exhaust emissions (generally increasing with age and use), engine
governors that are easily removed (anecdotal evidence suggests that in many cases
instructions are given by the retailer or manufacturer on how to remove the governor) and
are capable of higher speeds.

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.

Alternatively, petrol powered motors under 200W could be permitted. However, for this
to work effectively, a regime of testing and certification would need to be developed and
set in place so that users of these devices can be satisfied that what they are buying meets
legislative requirements. This regime would also be needed by enforcement agencies so
that they too can determine whether a particular device meets the requirements. It is
considered that the cost and logistics of setting up this type of regime (satisfactory to the
judiciary) would far outweigh any benefits in allowing petrol powered motorised scooters
to be used on road and road-related areas.


In summary, petrol engines, or more generally internal combustion (IC) engines, are noisier than
electric motors and it is unclear how many, if any, IC engines on the market are generating less
than 250 watts. On the other hand, mandating a particular power source restricts possible
innovations where the main objective from a road safety point of view is to limit the power
output, not the type of power source.

Is this worth protesting about ?
 
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This section is full of half-truths and misinformation.

It was written by someone who has no basis in engine modelling (or any practical experience).

A 7.5cc aero engine will do 375W @ about 20,000 rpm - full stick, flat out. And is designed to do this for a very short time before wearing out its ABC liner and dieing a very painful and noisy death. That is its peak redline power.

There are outrunner motors that are not much larger than a tennis ball that are capable of 2hp. The point in model aero engines are maximum power, minimum size and weight. They are not designed to last forever, just be cheap + powerful. Reliability and longevity is not even a minor concern.

The reason why larger capacity engines are used is that they have higher torque levels at low RPMs. A 31cc 2 stroke petrol engine will produce 248W at 2,250 rpm and 300W at 3000 rpm. It will also produce 750W (1hp) at 5,500 rpm. A modified centrifical clutch and reduction gearbox will achieve this easily, with either a throttle, exhaust or CDI restrictor.

From an engineering viewpoint, the compliance testing is a JOKE. They specify a dyno with a measurement granularity of 0.1KW (100W) - At 250W output, the dyno (depending on rounding and the fact that someone has to be pedalling (and adding power as well) at the time so there is assistance) may measure 0.2Kw or 0.3Kw so a compliant bike would measure as a non-compliant bike.

The measurement accuracy demands an accurate dyno that is capable of measuring 0.01Kw (10W) granularity.

Like I said, its very easy to pick holes in this.

A HT would have to be limited to ~1600 rpm (66cc, 250W) and ~2000 rpm (48cc, 250W).

The technical aspects of this report are pretty shakey.

It is interesting however, that they are not ruling out IC engines completly (like they did in QLD)
 
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It is interesting however, that they are not ruling out IC engines completly (like they did in QLD)

What he said. I'm not a Mechanical Engineer.
But this statement makes me think there's a glimmer of hope.

On the other hand, mandating a particular power source restricts possible
innovations where the main objective from a road safety point of view is to limit the power output, not the type of power source.
 
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).
 
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More...

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"To facilitate the enforcement of the PAPC definition, it is proposed to have a durable label affixed by the manufacturer in a conspicuous location to certify that the power-assisted pedal cycle complies with the relevant ADR definition. This would be simpler and more cost effective than requiring the Australian Federal Government to certify every PAPC model entering the country. Such a label is similar to the Canadian approach16."

This restricts users to purchase complete PABC's only, which restricts trade of compliant retrofit kits - in effect, making existing PABC's obsolete and
non-compliant.

"The labelling requirement would be issued by each Jurisdiction in a consistent way and will not be explicitly mentioned in the ADR definition. To ensure consistency across Australia, the requirements for an identification plate or adhesive label should be in accordance with the Australian Motor Vehicle Certification Board's Circular 0-3-2 'Identification Plates', except from
the need for an approval number. It is proposed that the durable label refers to an individual identification number permanently marked on the frame and the main components of the powertrain. Considering the high market value of some PAPC models, permanent identification marks would facilitate the retrieval of stolen PAPCs and render their rebirth more difficult."


If the labelling requirement is not explicitly mentioned, then it is not compulsary, and so makes the legitimising of stolen PABC's easier - Steal an unlisted PABC and list in in your name, or transfer the plates across between bikes, or make fake compliance plates, effectivly rebirthing. VIN/Plates are not a guarantee of rebirthing.

"For enforcement purposes, the maximum power output is verifiable with a motorcycle dynamometer as explained in the section 'Where to measure power'. A verification that pedalling is needed to get assistance from the motor will be sufficient to confirm that a PAPC is a vehicle designed to be propelled through a mechanism solely by human power to which is attached one or more auxiliary propulsion motors. This will assist with enforcing the provisions consistent with the result of the case Matheson v Director of Public Prosecutions17 where a person was identified as riding a vehicle deemed not to be a bona fide PAPC based on the fact that this person was
observed riding the vehicle while not pedalling."


The dynanometer stated in the section "Where to measure power" was shown to be unsuitable for the purpose, due to lack of granularity (and hence
innacuracies due to rounding and environmental factors).

The user must be pedalling to get assistance from the motor also needs to be taken into account in power measurement, or a human analogue of known (and calibrated power output) must be used.

"Observed Riding the vehicle without pedalling" - This does not take into account the ability of a PABC's need to be able to freewheel in order to be efficient. Perhaps the definition should read "Observed accelerating without pedalling at a rate not consistent with slope (ie. on a flat surface) or
power restrictions" and must be accompanied by a radar speed reading, and if called into question in a court, must be repeatable in the same circumstances.

Observation, then, is obviously not adequate to assume a breach of laws has occured, but the user must be able to demonstrate for the attending officer,
and if need be, to the prosecution, that the vehicle is not able to be used under power without pedalling.

"A heavier PAPC travelling at the same speed as a lighter pedal cycle will carry more energy in the case of an impact. The increase in energy is directly proportional to the increase in weight, therefore a PAPC and rider combination that is 25% heavier will carry 25% more energy, increasing the risk of inducing more damage in the case of a crash. Speed is significantly more
important in this scenario, where a 25% speed increase with the same weight would result in 56% more energy to be dissipated in a crash. The literature review that follows in the next section suggests that serious crashes between a pedal cycle rider and another vulnerable road user are
rare."


The next section goes on to say...

"In conclusion, the additional weight of PAPCs, compared to similar pedal cycles, increases the energy dissipated in a crash and can increase the braking distance when the braking system is limiting the achievable deceleration."

This basically states the obvious - adding more weight with a larger rider, or PABC equipment increases the braking distance on old bikes or bikes with inadequate brakes will increase stopping distances. But the same applies for
someone on an old bike with inadequate brakes who is overweight going down a hill - its irrelavent, and as the above states, serious crashes between a pedal cycle rider and another vulnerable road user (eg. pedestrian) are rare. A
cyclist is far more likely to have a serious crash due to the actions of a larger vehicle.

"A consequence of the proposed change to the PAPC definition may be to increase the number of cyclists on the roads by allowing a greater variety of products that can provide an increased assistance to the cyclist. A literature review has been conducted to better understand the circumstances of crashes involving bicycles and the effect of increasing the number of vulnerable road users on the roads."

The consequence of the proposed change will most likely REDUCE the number of cyclists on the road, having a reduction in the range and an increase in the prices of these products. Reducing the number of cyclists on the road will also have the negative effect of reducing safety for these cyclists, since other road users are less aware of their prescence. The literature review has already been done later in the report (??!) where it concludeds that more cyclists result in lower accident rates.

"The researcher's interpretation is that there is some real effect (on the probability of the injury being serious) of speed of motor vehicle (tending to be slower at intersections) and of relative velocity of the motor vehicle and the pedal cycle (tending to be less when they
are moving in the same direction), but that whether this shows up as statistical significance of one or more of the available variables depends on exactly which of these are in the equation."


Which is a good argument for not limiting the speed of assistance to 25Kph. It reduces the speed difference and hence effects on injury when the relaitve velocity of the motor vehicle and pedal cycle are moving in the same direction. Which is how they should be ridden LEGALLY (not against traffic).

"Pedestrians have taken issue with speeds at which cyclists travel on shared paths (Road Safety Council 1998a and correspondence from the Pedestrian Council). The current Australian road standards for design specify that shared paths must be able to accommodate the range of speeds at which cyclists travel, recommending that standard shared footways should accommodate cyclists travelling at up to 30 km/h, and that where it services a high proportion of commuting cyclists it should be up to 50 km/h (McInnes, 1998)."

PABC's should NOT be used on shared pathways UNDER POWER. Cyclists commuting at 50Km/h should be restricted to roadways. The relavence of this passage to this legislation is questionable.

"A study conducted in Oregon25, in the United States, found that crash rate for cyclists decreased with an increase in the number of cyclists. The number of cyclists in a particular area was monitored along with cycling crashes. The increase in cycling was partially due to an improvement in the quality of the infrastructure. The following table shows the improvement in pedal cycle
crash rate."


Unfortunatly a change in the legislation that makes a number of compliant PABC's now non-compliant will have the opposite effect - there will be fewer cyclists, and as a result, the crash rate will increase.

Here is the study mentioned above.

"The proposed definition would necessitate all new PAPCs to comply with a revised 'Vehicle Standard (Australian Design Rule - Definitions and Vehicle Categories)' from the implementation date. It should not be necessary to undertake a Regulatory Impact Statement regarding the increase in power output as this is a relaxation of the current situation. Similarly, the need to
pedal in order to obtain motor assistance is in line with the concept that the motor is auxiliary and human power is the main power source. The maximum assisted speed may be perceived as an additional restriction compared to the current situation and this issue would need to be discussed further. Once an agreement is reached and a timeframe is established for the modification of the ADR definition, the bicycle industry should be informed in a timely manner to allow for the manufacturing or import of products compliant to the new definition."


So what happens to the non-compliant products - may they still be used/sold but with a different compliance label (as per emissions standards/safety standards on automotive vehicles?) Just because vehicles didn't need catalytic converters in 1980 doesn't mean they cant still be registered/driven.
If so, how do you prove (without a compliance label etc) that the PABC was sold/built under the old ADR standards?

"Once vehicles that use electronics have passed EMC testing they obtain a European conformity mark (CE mark). According to the publication Bike Europe, all the e-Bikes (pedelecs) that are currently on the market meet the EMC requirements already in force throughout Europe."

The CE mark is now known in the electronics industry as the 'China Export' symbol. It is meaningless, and no guarantee of conformity.

The report then goes on to list compliant PABC's - all very expensive models.
 
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Awesome diagnosis Dr Young.

You'll make a fine lawyer some day.

On a complementary note,

I wonder if it would be possible to put a Aero Engine,
as per below, on a Bicycle somehow,
and see that it runs well at 5 km/hr.

This would demonstrate something,
I'm tired, you fill in the details for me...

copied from above
A 7.5cc aero engine will do 375W.
 
I'm back! I've been anticipating this RTA paper for over 12 months, and I'm glad that they have given me the room, terms of time, to clean my website up. Website is www.hybriped.com.

I'd appreciate any assistance that you can suggest to make it as user-friendly and factual as possible.

It's great to see that you guys are doing some good work discussing this. Heath - I've downloaded your analysis and I'll go throught with a fine tooth comb.

However, remember that this requires a political solution. We all need to think who might be interested in this and I think you'd be surprised who could be allies.

I've just updated some images on www.hybriped.com, so you will need to delete your temporary files to get the full effect.

The top banner says it all, for me. Sustainable Cycling Principle: pedal if possible, power-assist if practical.

In my view, the RTA paper has completely missed the 'practical' bit and when people see it, I think they will LOL.

I've set up an email information list papc50@gmail.com.

Interesting times!
 
...well I just want to wish all of you in Australia well in your struggle.

IMHO it is simply silly to import regulations from Europe or Japan, 2 much more densely populated places, into a much more wide open country. There is no reason why cities, the only densely populated places, cannot deal with these issues themselves and leave the rest of the nation alone....same here.
 
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