electric motorcycles, regulations
I've been looking into the regulations invoved in registering a prototype electric two wheeler. Specifically "Motorcycle single vehicle approval" which covers FFs.
It's chaos.
In the beginning there were the 1986 "Construction and use" and the associated 1986 Vehicle lighting regulations. The Voyagers were built to these regs. and they're not difficult to meet. Initially a vehicle could be built out of a scrapyard and once MOT'd, given a "Q" plate (e.g. FJ) Then there came the 'Single European act, 1990, which re-defined a lot of stuff and began Type approval, which evolved into "Whole Vehicle type approval", requiring very detailed specifications of each vehicle design - but were avoided by the "Single Vehicle Approval" (SVA)process, which repaced the Q plate process in Britain. Eventually Brexit came... By which time "Whole Vehicle approval" was in force and SVA had evolved into Motorcycle Single Vehicle approval(MSVA). This, you may be relieved to know, is based on the 1986 regulations. I think it's the one to work with.
None of these reguations define or specify electric powertrains.
There are contradictions. The 1986 regs demand that motorcycle fuel tanks are made only of metal. The 1990 Act sets a (UN)fire protection test that cannot be met by a metal fuel tank and plastic tanks beame legal. The 1990 Act defines a 'Motor Vehicle' as having four wheels among other things, allowing the Department of Transport to insist that motorcycles are not motor vehicles - and hence avoid regulations that refer to 'motor vehicles'... Current Type approval regs combine motorcycles in the Motor Vehicle definition. It is by no means clear which specific regulations are definitive(1986,1990,MSVA,2018)- or will be definitive after December 2020.
It's Brexit. No one knows anything.
However any MSVA-registered vehicle must first be inspected by an MSVA test centre, of which there are many around the country. I propose to take any relevent prototype design to my (Bristol) centre for their comment. It's the only sane approach, basically treating the MSVA test centre just like the Old Q plate MOT. You may need a vehicle Identification Number (VIN) from the DVLA, for an actual test, I'm not sure...
During the Voyager project we spent a lot of time getting to the bottom of the regs and I expect this will be needed now, but the government departments were quite helpful, even interested. It's a hoop-jumping excercise, not a battle. Perfect paperwork, as always, is the most powerful tool.
Anyone with an interest should do their own research, I'm not a natural beaurocrat! but there doesn't seem to be any obstruction to building an E-FF in these regs.
Here are the links I've used;-
https://www.gov.uk/government/publications/motorcycle-single-vehicle-approval-inspection-manual (The current version of the 1986 regs. as used in the MSVA)
approvals.technical@dvsa.gov.uk (Actual humans trying to be helpful)
http://www.legislation.gov.uk/ukpga/2018/18/contents/enacted (2018 Electric Vehicle Act, covers charging specs, may not apply to PTWs)
2002/24/EC: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:124:0001:0044:EN:PDF (Type approval regs. Will they survive Brexit? don't seem to apply to MSVA)
Let us know how you get on...
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1990 regulation
Hi Royce
Do you have a link to the 1990 regulations, which you mentioned, that define a motor vehicle as having 4 wheels.
Thanks, Martin
Links?
We didn't have no links in 1990 except the ones in a chain...
It's in the 'front page' definition of a 'Motor Vehicle' in the 1990 Single European Act. Of which I once had a paper copy. The D.o.T. used this definition to prevent us using plastic fuel tanks in the Voyagers. Although legal on 'motor vehicles' - and the only way to pass the UN test on fire resistance* for fuel tanks, for motor vehicles - the D.o.T. claimed that motorcycles, using the above definition were not motor vehicles and thus had to obey the 1986 CU, which required motorcycle fuel tanks to be made 'only of metal'.
I am eternally grateful to the D.o.T. for their unstinting and energetic opposition to anything to do with efficiency or safety in PTW's - or indeed innovation of any sort.
I am not clear whether the more recent type approval regs. that I referred to earlier, which include motorcycles in the motor vehicle definition, is seen as reversing the 1990 definition, or whether the 1986 CU, as used by MSVA regs, still requires a metal tank. And I very much doubt if this question has been asked in the D.o.T. (as if!). I seriously suggest that anyone planning to use the MSVA process locates their local MSVA test centre and works out any questions on the ground, in person. It's a waste of time to expect anything useful from central government. It's your MSVA test centre that will issue a registration, focus on them.
(I'm done with fuel tanks, although if I have to make another one it will be metal..)
*This test basically requires a fuel tank, with some specified amount of fuel in it, to be put on a fire for a minute, then removed, any fire extinguished, then be put back on the fire for another minute. Once removed and extinguised again, it mustn't leak.
Thank you
Thanks for that Royce.