LEVA-EU welcomes the report published by TRL and fka, at the request of the European Commission, regarding the need for harmonised rules for so-called Personal Mobility Devices (PMDs). The report formulates four regulatory options, with the fourth option being the development of a universal approval system for all PMDs. LEVA-EU also welcomes that this fourth option is recommended as “the solution which would provide the greatest benefit with the least disruption.“

A separate technical regulatory framework for all so-called PMDs is a solution that LEVA-EU has pursued since its inception. Unfortunately, the researchers elsewhere in the report, undermine this solution by adding other illogical and inconsistent proposals to the fourth option.

Contradictory proposals

For example, they believe that Electrically Pedal Assisted Cycles (EPACs) should remain within their current legal framework and only later be included in the proposed new PMD framework. The only reason they provide for this is that the current rules for EPACs are working. They do not mention that this specific EPAC-legislation prevents any other solutions for electric bicycles beyond pedal assistance limited by speed (25 km/h) and maximum continuous power (250 W).

These other solutions are now completely impossible because they fall under Regulation 168/2013. The reality clearly shows that type approval for these vehicles is unsuitable, as to date, no vehicles in this category, particularly L1e-A, are on the market. The call in the report to keep EPACs in their current legal framework is also directly contradicted by the researcher’s finding that “If both speed and acceleration are regulated, motor power is not relevant to the performance of the machine in any meaningful way.” Why they think that speed and acceleration should be regulated for some PMDs, while others should still have a motor power limit, is not explained in the study.

Vital threat to heavy carrier cycles

Another potentially very threatening proposal is to bring carrier cycles with a maximum permitted mass of 250kg under the L-category. By the way, there is no manufacturer of these vehicles listed among the stakeholders who provided feedback! If this plan is implemented, it would immediately spell the death of these types of vehicles, as they would be unable to comply with the technical rules of the L-category!

It is also particularly painful that this study was released to the press just as we, together with many other experts, were working in TC 333 – WG9 on the final European standards for carrier cycles. This has required a great deal of effort and hard work from a large group of people over five years. The fact that the study dismisses all that work with one stroke of the pen, and without further argumentation, is, to say the least, painful.

While fka and TRL were conducting their research into so-called PMDs for DG Grow, another department of the Commission, DG Move, was working on recommendations for future urban transport. Two historic recommendations were officially adopted, recognising Light Electric Vehicles (LEVs) as a separate vehicle category that warrants distinct technical requirements. These recommendations appear to have been overlooked by the researchers. LEVA-EU will urge the Commission to ensure that all decisions regarding technical legislation for LEVs (referred to as PMDs in the report) are made with due regard to these recommendations.

On December 9, the report will be officially presented to the Motorcycle Working Group. LEVA-EU will listen attentively and, after the presentation, will formulate an extensive position on this research.

Further information on the research and a link to the research are here: https://shorturl.at/3lW0M