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

Comments

Comment:
Class 1 (Pedal assisted e-bikes) are, first of all, expensive and not affordable to the majority of the cyclist, so there comes a discrimination. People who are lobbing this option only are those who have their own business interest and don't really care about public! Pedal assisted e-bikes are heavy and bulky and thus not meant to be used by a regular cyclist. For a cyclist that's a whole new "machine" affordable to "elite". These Class 1 e-bikes also have disadvantages with a standard bike chains being snapped due to increased stress caused by sudden increased torque. NYC should adopt a rules from the other states or countries (like California or Netherlands..) who have much more experience in this matter since, shame to say, NYC is "inventing a wheel" on this topic. It's an absurd to insist on safety and allow Class 1, whereas Class 2 (throttle-assist e-bikes) have the same speed and power limits. Yes, traffic rule violators should be punished or those who have e-bikes that exceed 20mph or 750W, but keep in mind that regular bicycle can exceed this speed of 20mph. E-bike controller is the key element that limits the power - speed of e-bike. Pedal assisted e- bikes can go way faster than 20 mph if controller doesn't limit the power. Same applies to throttle assisted e-bikes. Word “Factory certified” speed limit in the future law cannot prevent users to put different controller and “upgrade” their pedal assisted e-bike (same for throttle-assist e-bikes). It would make it difficult for police to examine and test if e-bike was modified. That is why the regulations should be focused on speed limit and motor power only, not pedal or throttle assisted. From my perspective, I find it discriminatory that I cannot use my own regular bicycle with a small 250W front hub motor (Clean Republic) with throttle button and 15mph speed limit without pedaling where the guy next door can cruise around with a $5000 pedal assisted bike because law allows only Class1. For me to buy another expensive pedal assisted e-bike, that can’t perform as a regular bicycle because it’s heavy and bulky, is not an option. From the prospective of the delivery drivers issues, I would like to suggest to legalize those throttle assisted bikes as long as they comply with 20 mph speed limit and 750W or 500W motor power. From technical point of view it is simple, affordable and possible to limit the speed of those thousands throttle-assist delivery e-bikes by changing a controller unit. Solutions would on the market within a weeks. Proposing a conversion from throttle assisted to pedal assisted is technically challenging, complicated and to simply say impracticable. So, if lawmakers are trying to propose this as a solution for existing owners of the throttle-assist e-bikes I would call it “sweeping the problem under the carpet” or ignoring a majority opinion that this issue concerns.
Supporting Document:
Agency: DOT
Comment:
This rule change is supposed to help delivery workers that make deliveries with a bike. However, most delivery workers use electric bikes that have throttles. Since these bicycles pose very little threat to public safety according to crash data, throttle powered electric bicycles should also be covered by this rule change. There is no reason to have throttle powered electric bicycles remain illegal. In fact, having them remain illegal is harmful to New York City because delivery workers are being punished for using them and they are encouraged to travel using more dangerous modes of transportation, such as motor vehicles. The additional benefit of throttle powered electric bikes is that they do not produce any air pollution because they are electric. More electric vehicles replacing gas guzzling motor vehicles would improve air quality our city.
Agency: DOT
Comment:
It has been illegal to use AND sell "Motorized scooters" (which includes class 2 e-bikes) since 2004. In spite of that, local bike shops have put thousands of illegal class 2 e-bikes on the streets --- and continue to do so. Regulations and fines banning their sale have NOT been effective. Delivery workers only use what they can purchase and get serviced locally. Why does NYC allow a handful of bike shops to openly flout the law, while cracking down on the "little guys"? As long as these shops are allowed to continue to sell illegal motorized scooters, delivery workers will continue to buy them --- if nothing else, because many of them do not speak English or understand our laws. They just assume that if they can buy it, it must be legal. In conjunction with this rule change, NYC also needs a coordinated, EFFECTIVE effort to either bring existing e-bike shops into compliance --- or put them out of business. If existing laws banning the sale of illegal e-bikes can be enforced, we will see a BIG increase in compliance on the street. We should not tolerate this continued type of lawlessness.
Agency: DOT
Comment:
I rely almost exclusively on my e-bike to get in and around NYC. It was formerly a Class 2 e-bike; but a year ago, I converted it to Class 1 by permanently disabling the throttle with some 5-minute Epoxy. My e-bike does not have a sticker stating power or top speed. I am concerned that the rules, as currently written, would make my bicycle illegal, forcing me to buy a new bike that is essentially equivalent --- simply for lack of an OEM sticker. There needs to be a way for existing e-bike owners to use their e-bikes legally, as long as they comply with the definition of "pedal assist bicycle."
Agency: DOT