Statement Regarding Potential CPSC Ebike Law Preemption of 3-class Legislation

Oberst

Well-Known Member
If you are OK with the federal standardization for automobiles, why would one definition for an ebike be troubling? We are talking about 750W (the average power of a two slice toaster) with speed controlled via a power limit at 20mph ensuring that ebikes really will not shift the bike speed distribution, only increase the average speeds and probably reduce the standard deviation a bit.
I think the equivalency for cars would be to have class one be cars with max speed of say 75 mph, class two would be any car with cruise control and three would be any car with max speed over 75 mph. Instead, all cars must follow local and Federal laws whether it be a Hyundai or a Lotus.
 

jabberwocky

Well-Known Member
Sorry. The CPSC is the Consumer Product Safety Commission. The essentially control the safety regulations for most consumer products sold in the US. Bikes were one of the initial products that were regulated by the CPSC which establishes a very long regulatory history.

Please understand I have nothing to do with the preemptive powers of the CPSC. I just feel strongly that the 3-class legislation crossed the line by pushing 3 requirements that had to be on ebikes prior to introduction into interstate commerce and that is simply crossing a regulatory line that should be preempted.
So what’s your end game here? I know a lot of people in bike advocacy, and the 3 class system is directly responsible for the rapid acceptance of ebikes in the traditional bike advocacy world. It sets limits on powered bikes that people are comfortable with. You seem proud of trying to throw it out, but I’m unclear why anyone who likes ebikes would think that’s a good thing. Undo that and it would undo a lot of advocacy.

What are you trying to accomplish?
 

Ken M

Well-Known Member
So what’s your end game here? I know a lot of people in bike advocacy, and the 3 class system is directly responsible for the rapid acceptance of ebikes in the traditional bike advocacy world. It sets limits on powered bikes that people are comfortable with. You seem proud of trying to throw it out, but I’m unclear why anyone who likes ebikes would think that’s a good thing. Undo that and it would undo a lot of advocacy.

What are you trying to accomplish?
Logically the commercial arrival of affordable Lithium Ion Batteries is behind the rapid acceptance of ebikes (It's nice that the marketing of 3-class claims credit but guess what? ... it simply isn't true ... not even remotely). Keep in mind there are 24 states that have not adopted 3-class and I'm sure the sales growth in those states is just a good as in the 3-class states.

I do not understand the statement that 3-class sets limits "that people are comfortable with." Would ebike buyers rather have a cease of assist at 20mph or a limit on the power at 20mph (per the constraints of 170lbs on level surface per the federal definition)? I have never heard a single rider make a positive comment about the riding experience of having the assist just end at 20mph. I do understand that it makes sense to limit speed of ebikes to keep them in the typical speed distribution of bikes (to be "use" regulated as a bike ebikes should not differ in typical speed distribution from a bike) but there are simply far better ways to use technology to limit the speed than a cut-off. I'm sorry if I'm not going to give a lot of merit to arguments made by lawmakers that they have pressure to keep pedestrians safe from bikers going faster than 20mph .... that is just political rhetoric and hysteria. On mixed use paths I do think that there should be speed limits for all bikes / scooters / etc. Why is it that the vast majority of us feel "comfortable with" speed limits on our roads / streets / highways / interstates (knowing some 3000 lb. super cars can exceed 300mph) and yet some of those same people want to apply a limit to a 750W ebike that has the power of the average 2 slice toaster below the speed I rode my bike as a 12 year old without a motor. I'm sorry if I'm putting some pressure on those supporting 3-class to logically support their position but it honestly it is long overdue. You need to present counterpoints and not just be critical of my lack of support for the 3-class legislation.

There is far better chances for much wider adoption of ebikes without 3-class and enforcement actually gets much easier because many ebikes are going with multimode settings and class stickers are just a joke (being sold in sheets so you can pick your "compliance").

My end goal is just a reversal to the federal definition for compliance and "use" like we still do with other bikes regulated by the same CPSC document as ebikes (in reality it limits ebikes to the speed performance of Class 3 even if the motor provides even higher peak power above 750W below 20mph). If you take the time to read the congressional notes taken when HR passed you will understand the intent was for the "low speed electric bicycles" to be consider a bike for use / traffic regulations. NO ONE has presented any safety data that shows we need 3-class and that is what is supposed to drive changes to CPSC regulations (not EU harmonization efforts via lobby money from companies that in a way don't want ebikes to get too many people out of their cars).
 
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Timpo

Well-Known Member
So what’s your end game here? I know a lot of people in bike advocacy, and the 3 class system is directly responsible for the rapid acceptance of ebikes in the traditional bike advocacy world. It sets limits on powered bikes that people are comfortable with. You seem proud of trying to throw it out, but I’m unclear why anyone who likes ebikes would think that’s a good thing. Undo that and it would undo a lot of advocacy.

What are you trying to accomplish?
@Ken M I have to agree here, I don't know what you're trying to accomplish.
I'm sure anyone here on EBR is all for whatever is good for ebikes, but I think many people are confused. :confused:

Could you paraphrase your analyses and proposal in one paragraph (if possible) without jargons or anything?
Because if you're actually trying to convince people, get a petition, whatever you do, it is important that your writing is short, simple and something that could be understood by everyone.

I don't know if I would, or how many people would want to be reviewing scholarly articles with 25+ citations like one that you posted.
 
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jabberwocky

Well-Known Member
Logically the commercial arrival of affordable Lithium Ion Batteries is behind the rapid acceptance of ebikes (It's nice that the marketing of 3-class claims credit but guess what? ... it simply isn't true ... not even remotely). Keep in mind there are 24 states that have not adopted 3-class and I'm sure the sales growth in those states is just a good as in the 3-class states.

I do not understand the statement that 3-class sets limits "that people are comfortable with." Would ebike buyers rather have a cease of assist at 20mph or a limit on the power at 20mph (per the constraints of 170lbs on level surface per the federal definition)? I have never heard a single rider make a positive comment about the riding experience of having the assist just end at 20mph. I do understand that it makes sense to limit speed of ebikes to keep them in the typical speed distribution of bikes (to be "use" regulated as a bike ebikes should not differ in typical speed distribution from a bike) but there are simply far better ways to use technology to limit the speed than a cut-off. I'm sorry if I'm not going to give a lot of merit to arguments made by lawmakers that they have pressure to keep pedestrians safe from bikers going faster than 20mph .... that is just political rhetoric and hysteria. On mixed use paths I do think that there should be speed limits for all bikes / scooters / etc. Why is it that the vast majority of us feel "comfortable with" speed limits on our roads / streets / highways / interstates (knowing some 3000 lb. super cars can exceed 300mph) and yet some of those same people want to apply a limit to a 750W ebike that has the power of the average 2 slice toaster below the speed I rode my bike as a 12 year old without a motor. I'm sorry if I'm putting some pressure on those supporting 3-class to logically support their position but it honestly it is long overdue. You need to present counterpoints and not just be critical of my lack of support for the 3-class legislation.

There is far better chances for much wider adoption of ebikes without 3-class and enforcement actually gets much easier because many ebikes are going with multimode settings and class stickers are just a joke (being sold in sheets so you can pick your "compliance").

My end goal is just a reversal to the federal definition for compliance and "use" like we still do with other bikes regulated by the same CPSC document as ebikes (in reality it limits ebikes to the speed performance of Class 3 even if the motor provides even higher peak power above 750W below 20mph). If you take the time to read the congressional notes taken when HR passed you will understand the intent was for the "low speed electric bicycles" to be consider a bike for use / traffic regulations. NO ONE has presented any safety data that shows we need 3-class and that is what is supposed to drive changes to CPSC regulations (not EU harmonization efforts via lobby money from companies that in a way don't want ebikes to get too many people out of their cars).
I’m not talking about consumer acceptance of ebikes, I said advocacy/institutional acceptance of ebikes. You know, the people who have been in the trenches fighting for bike access since well before ebikes existed. People whose work we are trying to piggyback onto.

I’m really unclear what the upside of what you’re trying to do is.

For instance, without the definition of class 1 bikes, ebikes would get zero traction in access to off-road trails. Ditch that and we lose trail access to a lot (probably almost all) trails that I currently can access on my class 1. You seem to be fine with this. I want to know why. What would we be getting in return?
 

Ken M

Well-Known Member
@Ken M I have to agree here, I don't know what you're trying to accomplish.
I'm sure anyone here on EBR is all for whatever is good for ebikes, but I think many people are confused. :confused:

Could you paraphrase your analyses and proposal in one paragraph (if possible) without jargons or anything?
Because if you're actually trying to convince people, get a petition, whatever you do, it is important that your writing is short, simple and something that could be understood by everyone.

I don't know if I would, or how many people would want to be reviewing scholarly articles with 25+ citations like one that you posted.
It is confusing and complex. I posted the full petition filed with the CPSC so anyone interested can read all the "citation" claims made.

The amazing thing about the CPSC is that their processes allow an unknown individual like me to file a petition that could have significant impact.

Ask yourself if a single definition for compliance and use is better than a 3-class system that was almost certainly the result of lobby money for regulatory capture. I believe I am as pro-ebike as anyone so I want the adoption of ebikes to reach their full potential especially urban mobility models.
 

Ken M

Well-Known Member
I’m not talking about consumer acceptance of ebikes, I said advocacy/institutional acceptance of ebikes. You know, the people who have been in the trenches fighting for bike access since well before ebikes existed. People whose work we are trying to piggyback onto.

I’m really unclear what the upside of what you’re trying to do is.

For instance, without the definition of class 1 bikes, ebikes would get zero traction in access to off-road trails. Ditch that and we lose trail access to a lot (probably almost all) trails that I currently can access on my class 1. You seem to be fine with this. I want to know why. What would we be getting in return?

The recent Department of Interior order 3376 states: E-bikes shall be allowed where other types of bicycles are allowed; and E-bikes shall not be allowed where other types of bicycles are prohibited. It's my understanding this order was issued to set the record straight on ebike use on federal land and national parks. I suggest everyone read this if they don't believe me. My guess is state parks will mimic this policy (will not make sense not to). This is in reference to both the federal definition and 3-class legislation so that is basically going back to the 2002 definition for compliance and use as my petition would do if the CPSC decides to preempt. You will not loose trail access of your Class 1 ebikes.

You should know that I did reach out to PFBs (I live like 20 minutes from the head quarters) and all I can say is that I didn't get a warm reception just asking a question about the PIM Archer ebike I owned that has a throttle and assists a bit past 20mph (thus per 3-class it's no long legal to ride on any public infrastructure in Colorado). You worry about their acceptance but maybe they should be more open-minded and willing to address questions on a legislative policy they are still hoping to get adopted by 24 more states.

I am an individual...just a self employed guy almost 60 that does the best he can. No one is paying me to do this. My research lead me to respect the federal definition that I believe was written by Dr. Malcolm Currie who had a vision about the potential of the technology (I'm working to meet him in California sometime in the near future to verify his intent ... he's like 92 years old but still working on EV projects as I understand it). I'm an engineer that ended up understanding the elegance of the federal definition and the somewhat silliness of the 3-class legislation (there is 0 real world difference to applying motor power via pedal-assist or throttle-assist yet 3-class implies there is because some totally non-technical people think throttles are "different"). I researched the regulations and simply came to the conclusion that 3-class was an overall negative for the industry and I have the right to petition the CPSC to review if mistakes were made adopting the 3-class legislation. It's a long read but I encourage everyone to read it and I'm guessing 80% will agree is should be preempted.
 

Ebiker01

Well-Known Member
The amazing thing about the CPSC is that their processes allow an unknown individual like me to file a petition that could have significant impac
Can u post the link to file the petiton so, that others can do it as well ? I will look it up online if I find it , i'll post it.
 

Ken M

Well-Known Member
@Ken M I have to agree here, I don't know what you're trying to accomplish.
I'm sure anyone here on EBR is all for whatever is good for ebikes, but I think many people are confused. :confused:

Could you paraphrase your analyses and proposal in one paragraph (if possible) without jargons or anything?
Because if you're actually trying to convince people, get a petition, whatever you do, it is important that your writing is short, simple and something that could be understood by everyone.

I don't know if I would, or how many people would want to be reviewing scholarly articles with 25+ citations like one that you posted.
Tim, The petition was filed as written in my initial post. I posted a couple surveys a while back and I think you did respond to one but overall there was not much feedback so I just went ahead with executing my plan to petition for preemption. Simply stated that means I'm asking the CPSC to end the standing of the 3-class regulation in all 26 states that have adopted it because primarily it violate their interstate commerce intent of their regulatory powers. Please look up how important explicit / expressed preemption is and note that it was part of the HR727 adoption of the low speed electric bicycle definition.

What I did was almost certainly inevitable especially with DeBlasio and Cuomo redefining Class 3 in NY. That state/city has been in "over-reaction" mode on ebike since the first pizza delivery guy used one. Their emotions have got the best of them on this subject. Now don't we all want to see their new policy preempted?
 

Ken M

Well-Known Member
Can u post the link to file the petiton so, that others can do it as well ? I will look it up online if I find it , i'll post it.
Actually numbers don't matter in their petition process - I just hope people feel I did the right thing if it succeeds (I wasn't going to file the petition unless I found legal precedent but I felt I did as part of the notes on a bike lighting decision made back in 1978 - cool it was same industry). Me filling is basically the same power as $100 billion corporation filing.

I knew very little about the history and policies of the CPSC but this one document is great if anyone is interested (if you invent a product you can literally submit the recommendations for it's safety regulations ... they want people to be involved): https://digitalcommons.law.villanova.edu/cgi/viewcontent.cgi?article=2262&context=vlr

But here's the link to what they refer to as the "consumer ombudsman" (Swedish for helper or something like that).

 

Ebiker01

Well-Known Member
Ty, i get all the legal terms you metioned and had read the posts.
Why can't we just have the "Law of Common sense"😉 ??

In retrospect what they do now with the division of ebike classes , it may be in order to set up a platform in order to bring insurance for class 3 ( no americans will buy a class 3 ebike If that will occur !). Also if we look at some recent very light class 1 ebikes(25-35lb) , one fit rider can easily outpower the motor above 20mph, turning his ebike into a class 3 human powered.

Are u saying that whether 1 individual or
5 file that petition , it could have the same outcome ? They may loose it , if it's only 1 .

ps: that's amazing that Mr. Currie is around !! I wonder what ebike does he ride ?
 

Ken M

Well-Known Member
Ty, i get all the legal terms you metioned and had read the posts.
Why can't we just have the "Law of Common sense"😉 ??

In retrospect what they do now with the division of ebike classes , it may be in order to set up a platform in order to bring insurance for class 3 ( no americans will buy a class 3 ebike If that will occur !). Also if we look at some recent very light class 1 ebikes(25-35lb) , one fit rider can easily outpower the motor above 20mph, turning his ebike into a class 3 human powered.

Are u saying that whether 1 individual or
5 file that petition , it could have the same outcome ? They may loose it , if it's only 1 .

ps: that's amazing that Mr. Currie is around !! I wonder what ebike does he ride ?
 

Ken M

Well-Known Member
"Common sense" I agree. What's funny is that the first time I read the federal / CPSC definition and thought it was strange but either written either by an idiot that got lucky or by a genius trying to achieve something (ie maximize performance without alarming the NHTSA who didn't want anything given to the CPSC that could go faster than 20mph). My curiosity as to the source of that definition and it's intent is how all this came about. It truly was intended to allow great utility below 20mph (higher power) while limiting power above 20mph (that power is defined by the dynamic power needed to sustain 20mph with 170lb rider on level surface - this is actually brilliant because it avoids assist cut-off while not enabling ebikes to be exceed historical bike distribution speeds). I've run the simulations to determine that wattage range for various ebikes and it's from 300-350W. Taking that dynamic power and then combining it with human power in the range of say 100 - 400W kind of peaks speed in the 25-30mph when you run the simulations. That's not crazy fast "compliant" speed capability but it's enough to allow wide ebike adoption for urban mobility.

I feel the class 3 was eventually going to require insurance as you also feel. That alone should be enough for everyone to support my desire for preemption.

No one else needs to file the petition. It's scheduled to be reviewed by CPSC's general counsel. I would want others to submit more petitions but I'm 99% certain it will not help.
 

Ken M

Well-Known Member
Ty, i get all the legal terms you metioned and had read the posts.
Why can't we just have the "Law of Common sense"😉 ??

In retrospect what they do now with the division of ebike classes , it may be in order to set up a platform in order to bring insurance for class 3 ( no americans will buy a class 3 ebike If that will occur !). Also if we look at some recent very light class 1 ebikes(25-35lb) , one fit rider can easily outpower the motor above 20mph, turning his ebike into a class 3 human powered.

Are u saying that whether 1 individual or
5 file that petition , it could have the same outcome ? They may loose it , if it's only 1 .

ps: that's amazing that Mr. Currie is around !! I wonder what ebike does he ride ?
....forgot to mention that I do hope to at least talk to Dr. Currie soon. I've been exchanging emails with his old partner's son and he's helping me in my research to confirm the original intend of the federal definition. I just have to know and then no one else's opinion will have much merit in my opinion because he was behind wrestling away ebikes from the NHTSA so all of us riders own him our gratitude.
 

jabberwocky

Well-Known Member
The recent Department of Interior order 3376 states: E-bikes shall be allowed where other types of bicycles are allowed; and E-bikes shall not be allowed where other types of bicycles are prohibited. It's my understanding this order was issued to set the record straight on ebike use on federal land and national parks. I suggest everyone read this if they don't believe me. My guess is state parks will mimic this policy (will not make sense not to). This is in reference to both the federal definition and 3-class legislation so that is basically going back to the 2002 definition for compliance and use as my petition would do if the CPSC decides to preempt. You will not loose trail access of your Class 1 ebikes.
Except nowhere I ride my class 1 is governed by that order. Its a mixmash of local, county and state parks and trails. I've talked to land managers in the past and have many friends involved with advocacy, and the class 1 definition is what is allowed. They explicitly do not want faster bike or throttles on any of their trails (which makes absolute sense). If the definition changes so that they would have to allow anything faster or anything with a throttle, I can say with relative certainty they would simply ban ebikes altogether.

The 3 class system is nice because it allows that granularity. I think class 1 is a reasonable definition for "anywhere a normal bike can go, this should be ok too". Class 2 is good for urban/city bikes; same power and speed but throttle allowed for quicker acceleration in stop and go situations. Class 3 is a nice "mostly riding roads" bike, and lets us have a faster option for people who don't use a lot of bike-only infrastructure.

What you have so far failed to really explain is what the advantage is of tearing down the 3 class system in states that have adopted it. Its widely accepted, manufacturers support it, much recent advocacy and access is built on it. You, for some reason, seem to have this burning desire to tear it down. Why? Ok, we go back to some older federal definition (that was put in place when ebikes were not really a thing and which no manufacturer seems to support). Why is this better, in your mind, than the system in place today?
 

Ken M

Well-Known Member
How about add a Class 4 for anything that doesn't fall into the Class 1-3 category instead of banging your head against a wall?
I'm not banging my head against the wall. The petition is filed and the CPSC general counsel will make a decision - it up to the lawyers to decide. I'm fine either way as if they decide that 3 class is acceptable then they will have to change the bike regulation to accommodate the classes. I do not think they will do that because they own interstate commerce / 1st sale. States have "use" which I don't think includes the right to redefine low speed electric bicycles into 3 (or 4 classes).

Think for a second, the federal / CPSC definition was in place and the vast majority of states adopted it (or less stringent which is allowed) and no issues for 12+ years. Then along comes this effort to harmonize with the EU and they tell everyone the 3-class system is about "clarity and improved safety" so that is needed for how ebikes are "used." Everyone just drank that koolaid and never really considered that the 3 classes made no sense except for harmonization.
 

PM Cycles

Member
Region
Other
Except nowhere I ride my class 1 is governed by that order. Its a mixmash of local, county and state parks and trails. I've talked to land managers in the past and have many friends involved with advocacy, and the class 1 definition is what is allowed. They explicitly do not want faster bike or throttles on any of their trails (which makes absolute sense). If the definition changes so that they would have to allow anything faster or anything with a throttle, I can say with relative certainty they would simply ban ebikes altogether.

The 3 class system is nice because it allows that granularity. I think class 1 is a reasonable definition for "anywhere a normal bike can go, this should be ok too". Class 2 is good for urban/city bikes; same power and speed but throttle allowed for quicker acceleration in stop and go situations. Class 3 is a nice "mostly riding roads" bike, and lets us have a faster option for people who don't use a lot of bike-only infrastructure.

What you have so far failed to really explain is what the advantage is of tearing down the 3 class system in states that have adopted it. Its widely accepted, manufacturers support it, much recent advocacy and access is built on it. You, for some reason, seem to have this burning desire to tear it down. Why? Ok, we go back to some older federal definition (that was put in place when ebikes were not really a thing and which no manufacturer seems to support). Why is this better, in your mind, than the system in place today?
Finally! This was long overdue, I really hope the 3-Class System is destroyed forever. I always felt the potential motivation when People For Bikes introduced Class 3, was to eventually extract insurance/registration on E-Bikes. The insurance lobby money would be HUGE amounts. The insurance industry has been drooling to get their teeth into bike insurance for a century. Note - This is already a done deal in Europe, (EU "Speed Pedelec" = harmonized as Class 3 in US by P4B). I don't know about anyone else, but I despise insurance companies aka - Dispute/Delay/Deny. I'm sorry People For Insurance, but no one wants insurance mandatory on E-Bikes! Also, in April, 2019 the Bike Product Suppliers Association joined with People For Bikes. It seems strange to me that an organisation called "People For Bikes" (pretty Orwellian) admitted that they took lobby money from Bosch? Is P4B promoting the interests of people or are you promoting industry? This is a blatant example of regulatory capture done sloppy. On a side note - Bosch is the #1 auto parts supplier in the world and made 85.9 billion on car parts last year. So the true strategy and motivation of of auto suppliers is to control the pace of E-Bike adoption. Make them just slow enough (Class 1/2) that you're forced to get into your car and wear out your fancy Bosch brake pads, because some cyclist on a slow E-Bike is in the middle of the damn road! Class 3 option is faster but will be expensive (insurance - eventually in class 3). Bosch is reducing the competitive edge of E-Bikes for corporate profit. They don't want E-Bikes to compete too much with their existing revenue stream. Can you blame them? How many chain rings, derailleurs and motors would you need to sell to replace that 85.9 billion? However, do we really want the #1 Auto Parts supplier in the world influencing our E-Bike policies? The ONLY people that seem to like the Class System are the big players, who coincidentally seem to also sponsor People For Bikes. Car and motorcycle parts make up 90% of Bosch's revenue, as well Brose only receives 0.5% of its profit from E-bike motors. BOTTOM LINE - Bicycle parts DON'T bring in the margins, hate to say it - but it seems that's the real truth. They are controlling the pace of E-Bike adoption and steering the revenue via regulatory capture - it's really not rocket science. There are also other reasons too, industry set the standard in the EU at 250w motors to gain market share over the Chinese hubs (to reduce competition in the EU market at the time). Anyone in the industry knows that a 250w rear hub is NOT competitive with the mid drives. This is how the world of big business operates. Why is ANYONE defending People For Bikes? Why would anyone have loyalty to them? If you want to buy insurance and registration, then stick with them.

Do you want to know what the future looks like if People For Bikes win? When the EU passed insurance on their fastest class, no one bought them. So the EU decided to reduce the speed of their other classes from 20mph to 15mph as to force people into the faster bikes requiring insurance / registration (sound familiar?). And guess what has happened? E-Bike sales have stalled in Europe and legislators are AGAIN revisiting on making changes to EU E-Bike laws. So maybe see you all here in a few years again?! Haven't Americans had their fill of insurance already? Do you really want more?
 
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jabberwocky

Well-Known Member
As far as I'm aware, no state has even discussed (much less considered legally requiring) insurance on any ebike, nor is it a plank at any advocacy org, including PFB. The whole "the 3 class system is a back door conspiracy to require insurance" comes across as entirely tinfoil-hat to me, at least in the US.

Seeing industry support of advocacy orgs as some sort of conspiracy just says you have no experience in bicycle advocacy. Its a pretty normal thing and long predates ebikes. Expanding access expands the market, whether its increased legal access for ebikes, more trail for mountain bikes, better commuting infrastructure, etc. The more people riding, the more potential customers for your product (and its good PR as well). The idea that Bosch is trying to cripple the ebike market to help their car business is just... ludicrous? If nothing else, Bosch has a ton of competition in the motor market, so its not like people don't have a choice if they don't like what Bosch is pushing.
 

Mr. Coffee

Well-Known Member
Region
USA
City
A Demented Corner of the North Cascades
I would be interested to see what an attorney who specializes in such issues thinks of this statement. I'd be even more interested in hearing from people actively involved in advocacy for bicycles about what they think of it.

My own guess is that this statement is unlikely to accomplish anything at all, and if it does accomplish anything it is unlikely to benefit e-bikers.

In the unlikely event that a ruckus was produced, I think the end result would be that regulation of e-bikes would be disconnected from CPSC and move to DOT (probably NHTSA). Again, I find it hard to imagine that many of us would find our lives improved by that change.