LEVA-EU Position on Review for Zero Emission Tailpipe VehiclesComments Off on LEVA-EU Position on Review for Zero Emission Tailpipe Vehicles
LEVA-EU has published a position paper in which the trade association has developed an exhaustive argumentation for the introduction of the concept of Zero Tailpipe Emission Vehicle (ZEV) in Regulation 168/2013. The ZEV-concept covers all light, electric vehicles and allows for much simpler, more accurate and future-proof rules. LEVA-EU has submitted the paper to TRL in the framework of their on-going study for the European Commission.
LEVA-EU defines a Zero Tailpipe Emission Vehicle as “a powered vehicle equipped with a motor that does not produce harmful tailpipe emissions”. Next, LEVA-EU proposes to add an article to Regulation 168/2013 stating “This Regulation does not apply to Zero Tailpipe Emission Vehicles with a maximum design speed not exceeding 50 km/h;” Furthermore, LEVA-EU proposes to exclude all Zero Tailpipe Emission Vehicles from the Machinery Directive. As a result, this simple legal intervention would exclude all types of electric cycles, e-scooters, monowheels, e-hoverboards, self-balancing vehicles and any other Zero Tailpipe Emission Vehicle not yet mentioned explicitly in law today, from the current legal framework, which is totally inappropriate and inaccurate.
Instead, LEVA-EU proposes to transfer ZEVs into a new horizontal Vehicle Regulation. This European law would specify essential safety requirements to be complemented with harmonised standards and possibly, for certain ZEV-categories, type-approval procedures. In any case, LEVA-EU believes that the form of the legislative framework needs to be decided in consultation with the ZEV-sector.
LEVA-EU’s proposal for new legislation is based on kinetic energy, which equals 1/2mv². LEVA-EU believes that vehicles developing similar levels of kinetic energy must be subject to similar rules. It is unjustifiable to submit vehicles with the same kinetic energy to completely different rules as is the case today.
As an example, a pedal assisted bike 25 km/h – 250W develops exactly the same kinetic energy as that same vehicle with for instance 300W. And yet, the first is excluded from type-approval, comes under the Machinery Directive and has the same status as a conventional bicycle in all Member States. The 300W edition is an L1e-A, needs type-approval and does not have a clear status in most Member States. The first one is selling by the millions, the second one is virtually non-existing.
Very simple categorisation
Following on to this principle of kinetic energy, LEVA-EU proposes a very simple categorisation based on speed and weight only. There would be a distinction between vehicles with a maximum speed of 25 or 30 km/h and vehicles with a maximum speed of 45 or 50 km/h. LEVA-EU insists that the limits must be set in consultation with the ZEV-sector. There may well be an argument for 30 and 50 km/h because this is in line with speed limits used by road management authorities. It would make it easier for ZEVs to go with the flow of the traffic, whilst today through their design they have slightly lower speed limits of 25 and 45. These have never been decided upon any scientific or other research. They were just copied from conventional mopeds.
LEVA-EU proposes to split up the two speed categories in low-weight and higher-weight vehicles. Again, the limits should be set in consultation with the ZEV-sector. The low weight and low-speed vehicles would be regulated by the provisions of the new, horizontal Vehicle Regulation in combination with harmonized standards. LEVA-EU points out that there are already a number of standards available and others in preparation. For the 3 other categories, LEVA-EU leaves the option open of Vehicle Regulation plus harmonized standards or specific type-approval. Again, the decision needs to be made in consultation with the ZEV-sector.
Call for consultation
Throughout the position paper, LEVA-EU really stands up for a better representation of and consultation with the ZEV-sector. Today, the forum for preliminary discussions on the corrections, amending and review of L-category type-approval legislation is the Motorcycle (sic) Working Group. This forum is dominated by internal combustion engine moped and -motorcycle experts, both among the Member State representatives and the stakeholders. LEVA-EU is the only stakeholder to exclusively represent ZEV-companies.
In the Motorcycle Working Group a number of stakeholders are fighting to keep the technical rules as they are. That is proof in itself of the extent to which these rules prevent the development and marketing of ZEVs. With that, the organizations totally deny the fact that new types of ZEVs are needed to address new types of users, to convince even more people to trade unsustainable mobility for sustainable mobility by means of ZEVs. Electric bicycles with a throttle for instance have the right to exist, for instance for people who are physically incapable of pedalling all the time, as needed with pedal assist only. In the case of carriage of goods and people, the obstruction caused by current regulations and the need for new concepts/solutions is even bigger. Because the voice of the ZEV-sector is drowned out by the voice of parties who consider ZEVs an existential threat, from which they must protect their business, the Commission has not (yet) entered into an in-depth dialogue with the ZEV-sector. LEVA-EU calls on the Commission to no longer postpone that consultation.
Regulate speed differently
Some member states don’t have dedicated speed limits on cycle paths/cycling infrastructure. LEVA-EU believes that member states must impose maximum speed limits specifically on cycle paths, which need to be used in a smart way. These limits should still allow to achieve and not to hinder the potential of the ZEVs. For instance, on a separate wide, good quality path with low traffic, the speed limit should allow non-low speed ZEVs such as speed pedelecs to use their full potential. All ZEVs should then be given the option to use cycle paths provided they keep to the maximum speed and whilst observing potential local rules on dimension limits. If they want to go faster, they must go on the road, provided the speed limit there does not exceed the ZEV speed limit by design. Another example: in cycling streets a speed limit of 30 km/h or even lower may be imposed, whilst all ZEVs both low and non-low speed are allowed on condition that they keep to that local speed limit.
Regulating speed through local speed limits rather than through the design of the vehicle, just as is the case for all other vehicles, will improve the access to different types of ZEVs and therefore reduce the desire for increasing the vehicle’s speed limit by tampering. It will also simplify the policing of speed limitations for ZEVs.
All ZEVs up to 5O km/h should be subject to the same traffic rules as bicycles, for instance allowed to ride in two directions in one-way streets for motorised traffic, allowed to turn right at traffic lights, allowed to use waiting areas in front of motorised traffic at traffic lights, allowed to ride in front of motorised traffic in “cycling streets” etc. Obviously, those facilities should only be granted if feasible. In this respect, it may be necessary to consider dimension restrictions for certain use. With that however, it is important to strive for a European harmonized approach so as not to create a new bottleneck that hampers free circulation of goods in the single market.
No more cycle paths
LEVA-EU also calls for renaming all infrastructure, now known as cycling infrastructure, such as cycle paths, cycle streets, cycle highways, cycle parking, etc. as ZEV infrastructure. Member states must not only rename the infrastructure, but they also need to redesign traffic signs, traffic pictograms, etc. to represent all ZEVs instead of bicycles only. This will improve cyclists’ and motorists’ perception of ZEVs. Today, cyclists often feel that the infrastructure is their exclusive territory and, when the infrastructure is scarce, they consider other ZEV-users as intruders. This results in irritation and in the worst case in conflicts. Motorists are not yet used to the fact that, today there are many more different light vehicles on the road than just bicycles. Renaming and resigning infrastructure may well contribute to raising their awareness of the changing traffic scene.
Member states must consult
LEVA-EU invites all ZEV-stakeholders to read the full position paper and to respond to it. You can find it here: https://bit.ly/36SrBwv
Let us know whether you agree with our proposals or whether you have ideas to further improve our proposals. Please send your reactions to LEVA-EU Manager Annick Roetyck, firstname.lastname@example.org.
Overview of LEVA-EU’s proposal
Speed in the table below is the maximum speed at which the motor propels the vehicle with or without addition of muscular power
|Maximum limit to be determined in consultation with LEV-sector||25/30 km/h to be set in consultation with LEV-sector||Horizontal Vehicle Reg. + Harmonized standards||Identical to (e)-bikes – but no use of dedicated low-speed ZEV-infrastructure above specified width – no helmet obligation if more than 2 wheels and ROPS|
|Maximum limits above limit set in previous category to be determined in consultation with LEV-sector||25/30 km/h to be set in consultation with LEV-sector||Horizontal Vehicle Reg. + Harmonized standards or Specific Type-Approval for these vehicles||Identical to (e)-bikes but no use of dedicated low-speed ZEV-infrastructure above specified width – no helmet obligation if more than 2 wheels and ROPS|
|Maximum limit to be determined in consultation with LEV-sector||45/50 km/h to be set in consultation with LEV-sector||Horizontal Vehicle Reg. + Harmonized standards or Specific Type-Approval for these vehicles||Possibility of (e)bike helmet – use of LEV-dedicated infrastructure only up to maximum speed as decided by local traffic management authorities – specific theoretic driving licence exam – if practical exam than specific for and with vehicle concerned|
|Maximum limits above limit set in previous category limits to be determined in consultation with LEV-sector||45/50 km/h to be set in consultation with LEV-sector||Horizontal Vehicle Reg. + Harmonized standards or Specific Type-Approval for these vehicles||no helmet if ROPS – use of LEV-dedicated infrastructure only up to maximum speed as decided by local traffic management authorities and under specific width – specific theoretic driving licence exam – if practical exam than specific for and with vehicle concerned|
|Vehicle type and speed||Kinetic Energy in Kilojoules, assuming rider weight 70 kg|
|Human running without vehicle, 25 km/h||1.69 KJ|
|Very Lightweight Bicycle or Electric Vehicle, 10kg riding at 25km/h||1.93 KJ|
|L1e-A powered cycle 500W, 25kg, e.g. throttle up to 25 km/h, riding at 25km/h||2.29 KJ|
|Electrically assisted cycle 250W, 25 kg, assistance up to 25 km/h riding at 25km/h||2.29 KJ|
|Electrically assisted cycle, 25 kg, assistance up to 25 km/h, riding at 30 km/h||3.30 KJ|
|Very Lightweight Bicycle, 10kg riding at 35km/h||3.78 KJ|
|Moped (L1Be), 50kg riding at 45 km/h||9.37 KJ|