Submission of response to Gov Consultation re E-BIKES (due before 26.4.24)

Cumbria Cycle Mayor (Richard Ingham) has posted today information about the above. Submissions are to be in before the end of Thursday.
The proposed changes are to increase the Wattage permitted (for pedal cycles and so called EAPCs - electrically assisted pedal cycles) from 250 to 500 watts, and allowing 'twist and go' operation. 

In view of the limitation in time I have drafted an outline of my thinking which I show below. I don't think my views are likely to be controversial for Club members (a brave expression). 

PLEASE, please would you have a check through, even look at the regulation summary (I am not sure that you will make this link work but I am sure I have got all the right letters if not necessarily in the right .....) letting me have any contrary views.

https://www.gov.uk/government/consultation/smarter-regulation-proposed-changes-to-legislation-for- electrically-assisted-pedal-cycles

Smarter regulation: proposed changes to legislation for electrically assisted pedal cycles (EAPCs)

(issued 29.2.24 response closing 2359 hours 25th April 24)

Questions:                                          Suggested (abbreviated) responses       

1	Support / oppose:	Oppose
2	Explain response:	removal use of pedals / twist and go more akin to motorcycles ..
3	provide relevant evidence	Cycle Club with substantial e-cycles membership
4	Support / oppose increase in assisted speed from 3.73 Kmph to 25 Kmph	Oppose (current no pedal / electric max speed 3.73 km.  250 Watt has the present limit of 25km)
5	Explain answer to 4	If no pedals only power is the electric motor. There are no physical exercise benefits for a cyclist  (with exception for hand propelled cycles, usually 3 or more wheels, but equally they would not be exercising with EAPC).
6	Provide evidence in support of answers 4 & 5	(Club cycling issues)
7	You propose limiting to disabled  ?	No / not relevant –EAPCs are simply motor vehicles
8	Support / limit to cargo bikes? Definition asked for (!).	No experience but 250 watt powers large Off road bikes without apparent lack of power
9	Evidence sought for 8 answer (Q excludes answer re vehicle insurance , Highway Code, helmets ...)	As above
10, 11, 12, 13	What is stock in UK and use of e-cycles  ? the e-cycle market ....	Don’t know
14	Change in Regs affecting ‘function and performance .. no of trips taken’ for consumers and transport users	Imagine some irresponsible use will engage urban dwellers in perfecting side-stepping , better falling performance and First Aid practice
15,16	manufacturers' responses - costs / benefits .....	Don't know