Public comments for: DOT Notice of Public Hearing and Opportunity to Comment on Proposed Traffic Rules--Pedal Assist Bicycles

Comments

Comment:
There have been positive initiatives in NYC toward e-bike safety and legalization. But while Mayor de Blasio took a step toward justice after classifying Class 1 pedal assist e-bikes as bicycles, he must expand his efforts to include Class 2 throttle-assist e-bikes. The bikes are substantively similar: both pedal assist and throttle assist bicycles — as well as normal bicycles for that matter — can reach top speeds above twenty mph. Criminalizing one and not the other sustains an unjust hierarchy of bike ownership and usage without rational basis. In New York City, it also happens that this criminalization preys on some of our city’s most vulnerable workers. The majority of the people who use throttle assist e-bikes are immigrant workers delivering food. Because the vehicle is not just a bicycle but a source of their livelihood, it is especially important to safeguard them against onerous regulation. Such measures are predicated on little other than their protected class and opprobrium directed at work that members of the community disfavor despite its essential role in the economy of the city. Since the city already deemed pedal assist e-bikes legal, then all e-bikes that meet safety standards should be legal and encouraged. Concerns with the safety of these bikes cannot be distinguished adequately and again it is concerning that a disfavored class of riders continue to be stigmatized. A simple measure such as ensuring that e-bikes travel under 20 miles per hour will ensure that they cause problems commensurate with those involving non-electronic and pedal assist bikes. Legitimizing e-bikes offers benefits beyond those involving e-bike riders. By continuing to target throttle e-bikes, New York City encourages more cars at a time when congestion is reaching a climate tipping point. The Mayor is incentivizing congestion when it should be incentivizing a smaller carbon footprint and cleaner air. At a time when congestion issues plague our city, and will only be exacerbated by the L-train shutdown, we should be encouraging all alternative forms of low-emissions transit. E-bikes need only ten percent of the energy required to power a car, and are six times more efficient than rail transit. Until all e-bikes are legalized, the city will be hindering its own chance at developing a low carbon energy efficient transit network we so desperately need. If NYC wants to be a climate leader, it must now follow the example of global cities such as Paris and San Francisco that have acknowledged the benefits and encouraged the adoption of all types of e-bikes that offer benefits to public health while delivering few or no additional risks to public safety. I call on the Department of Transit to rectify this dichotomy and bring all e-bikes into rightful legal standing so that they can be part of a safe, energy efficient New York that works for all.
Agency: DOT
Comment:
Dear DOT, I would like to commend the mayor and the DOT for working to legalize the usage of electric bikes in NYC and to clarify the rule regulating their use. We should focus our sight on what we strive to do, which is to make NYC a safer place for all and to do so at the minimal cost to individuals and businesses. E-bikes can be part of an ecologically sound solution to the traffic issues in New York City, and they can be used safely if we regulate it effectively and without bias. At the end of the day, what really cause traffic accidents and injuries are speeding and disobedience of traffic rules, not throttle or pedal assisted electric bike. I believe it is much more feasible and effective to treat bikes (electric or not) as just a fast moving, human driven vehicles that need to be handled with care, and regulate them as such. This will save all the confusion surrounding implementation and enforcement of these rules. The clarification of the regulation will undoubtedly help all users in the biking community, recreational or commercial, but the detail in implementation and enforcement could make the new rule ineffective. So I would recommend modifying the rule and focus not on the technical detail of the vehicles, but the effect of that technology have on the commuting environment. Furthermore, I think it makes sense to have a moratorium on issuing traffic summons based on electric bike ban until the new rule is adopted so that communities that rely on the electric bike for their livelihood can get a fair chance to be compliant with the law. I believe that is a win-win for everyone.
Agency: DOT
Comment:
An alliance of cycling advocates have proposed changes to the e-bike law that would enable the conversion of existing e-bikes to Class 1 legal status. Implement the changes proposed by cycling advocates to ensure there is room to convert the majority of existing e-bikes that delivery workers already own and use, then let's partner to fund and distribute affordable, simple conversion kits.
Agency: DOT
Comment:
Is an all-electric car legal? (yes; Tesla's are obviously legal, and many policies exist to promote and accelerate adoption of all-electric vehicles) Surely then an all-electric bike which is speed capped at twenty miles per hour on a road with a twenty five mile an hour limit should also be legal.
Agency: DOT
Comment:
This rule change is long overdue--pedal-assist e-bikes will, as stated above, greatly improve mobility for New Yorkers (those who can afford them, at least). It is, however, unjust to sanction only pedal-assisted ebikes, which cost far more than the throttle models used by the folks who deliver our food. It has been heartbreaking these past months to see and hear about the NYPD's seizure of their means of making a living. I don't deny that many pedestrians are afraid of speeding delivery workers, but it makes no sense that simply owning an ebike, a necessity for their jobs, can cost a delivery worker over $500. As a comparison, a ticket for speeding in a school zone costs $50. I work in physics, but I don't think one has to be a physicist to figure out that a 2-ton SUV traveling over 25mph is far more dangerous than a 300lb ebike at 20mph. In addition to the proposed rule change, please also allow an exemption for throttle ebikes that have a governor to cap speeds at 18mph, as shown at today's meeting. Regardless of their immigration status, delivery workers are fellow New Yorkers who deserve our respect.
Agency: DOT
Comment:
As a father, husband, daily bike commuter from Brooklyn to Manhattan and son of Chinese immigrants who when they first came to the United States ran Chinese restaurants so they could provide a better life for me and my brother-- I feel a special connection to many of the hard working ebike deliverymen trying to make a better life for themselves and their families -- in many ways, they truly are the embodiment of the American dream. Which is why it is imperative in the Age of Trump that we end this class based and xenophobic persecution as this ebike crackdown is not supported by facts, reason or the objectives of public policy. At at time when truly progressive cities that are far more advanced on Vision Zero goals, such as London, Paris, Stockholm and Copenhagen, are actually subsidizing ebike ownership (including for business deliveries [see photo attached of non-ebike from downtown Brooklyn]) as a congestion disrupter and car substitute (not just a bike substitute) we must not allow the kvetching of NIMBYs drive policy. We must follow the data which is precisely why embracing ebike ownership (not just pedal assist) is imperative for achieving so many of the Council's shared goals. You name it: Climate Change, Vision Zero, Congestion, Fossil Fuel dependency, enhanced mobility in transit desert and yes, even the L-train shutdown; can be ameliorated by ebike promotion. And as a daily bike commuter I promise you, the occasional "buzzing" from an ebike deliveryman is nothing compared to the near misses from cars and trucks on a near daily basis. I certainly understand how ebikes "feel" unsafe to many people -- but the realty is and statistics clearly show -- they are not unsafe as it is cars and trucks that kill people in NYC on a regular basis, including but not limited to Edwin Ajacolon less than 50 feet from my house last November. 4-year-old Abigail Blumenstein and one-year-old Joshua Lew were killed by a car driver less than 15 blocks from my house this March, and it was a garbage truck driver who killed my immigrant grandparents approximately 40 years ago. Please let sensible policy carry the day and legalize what is a safe, green, efficient, space minimizing, cheap form of transportation. Thank you.
Supporting Document:
Agency: DOT
Comment:
While I welcome the city's efforts to remove restrictions on use for electric bicycles ('e-bikes'), the proposed rule changes only legalize a subset of e-bikes currently in use on our streets. To create a distinction between pedal-assist and throttle e-bikes not based on any particular difference in operation of these vehicles, especially when no data has been presented to justify this distinction, is arbitrary. The City's recent targeted enforcement of the current rules regarding e-bikes and the origins of this enforcement strategy suggest that it and the distinction in the proposed rules are motivated by animus towards those riders who use e-bikes with throttles that does not exist towards those who use pedal-assist e-bikes. The mayor, at the press conference to announce this strategy, claimed that fines for violating the current rules would go to restaurants who employ riders who use e-bikes with throttles, but no evidence that the fines have gone to businesses and not to the riders themselves has been seen. That the enforcement has focused on low-wage workers rather than their employers should make it clear that these rules are intended to allow those fortunate enough to be able to buy expensive pedal-assist e-bikes to do so, while continuing to penalize those who are not. Any proposed rule changes and distinctions therein should be based on data, and the city has made no case, let alone a convincing one, why e-bikes with throttles should be treated any differently than pedal assist e-bikes.
Agency: DOT
Comment:
At a time when congestion issues plague our city, and will only be exacerbated by the L-train shutdown, we should be encouraging all alternative forms of low-emissions transit. E-bikes need only ten percent of the energy required to power a car, and are six times more efficient than rail transit. The city should allow all forms of e-bikes and regulate them to remain safely under twenty mph. I hope this rule change brings all e-bikes into rightful legal standing in order to make a safe, energy efficient New York that works for us all.
Agency: DOT
Comment:
No matter what rule the city ends up adopting, it should forbid the NYPD from ever seizing bikes. Police don't even seize many cars and trucks involved in fatal collisions. It is cruel and unusual punishment, as well as a violation of due process, to seize people's means of livelihood out from under them.
Agency: DOT
Comment:
Pedal-assist bikes (Eg, those that do not have a throttle and go no more than 20 mph) should be legal since they are no more of a threat to pedestrians, vehicles, and cyclists, than ordinary bicycles. Anything larger/faster than that should be legalized too, but with a VIN number and license plate as if it were a motorcyclre.
Agency: DOT

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