The public comment period on proposed changes to Mass. Department of Conservation and Recreation rules as it pertains to electric bicycles remains open until Wednesday July 24 at 5pm.
302 CMR 11.00: Parkways, Traffic, and Pedestrian Rules and 302 CMR 12.00: Parks and Recreation Rules, would prohibit usage of electric bicycles on all natural surface trails, improved trails that are less than 8’ wide and on dirt roads that are not open to vehicular traffic.
Read below for why we think this issue is important at this juncture and for instructions and a sample e-mail script to provide your comments.
Bicycling (as most of you already know!) improves physical and mental health, provides a connection to the community, and is a tool to access nature and open space -- as well jobs, school, groceries, healthcare and much, much more. Electric-assist bicycles help those who otherwise wouldn’t (or couldn't) get on a bike. No matter the reason, e-bikes provide an opportunity to get more bicyclists out riding.
Currently, the bicycle advocacy community is struggling to figure out how e-riders fit in the same space traditionally allocated to standard bikes. Amid concerns mainly due to speeding and shared path etiquette, we are seeing suggestions, like the proposed changes from the DCR, for blanket prohibitions to prevent e-bike riders from pathways and trails, equating them with motorcycles and mopeds.
At MassBike, it's our charge to mitigate those issues to keep access open for e-bike riders. At a recent hearing held by the Dept. of Conservation and Recreation (DCR) on the issue, an attendee fighting Parkinson’s disease put it well by stating “this wouldn’t be a prohibition on bikes, it’s a prohibition on people.”
We urge you to join in the conversation on this topic.
DCR is proposing regulations that would pertain to pedal-assist bicycles. We appreciate the desire for the DCR to allow Class-1 Pedal-Assist Electric Bicycles on improved trails over 8' wide (like rail trails). However, we disagree with the proposal to prohibit the use of pedal-assist bikes on "improved DCR trails that are less than 8 feet in width, dirt roads that are not open to vehicular traffic, and any natural surface trails, regardless of width or other conditions."
We have some requests:
- In order to provide clarity on the devices we're regulating, DCR should follow the 3-class model that define the types of electric bicycles, or hold off until we can get our legislation through that would create a classification system in Massachusetts. Read more about the 3 class system and this legislation here.
- DCR should look to allow Class-2 and Class-3 electric bikes where appropriate on paths and roadways, and DCR should look to allow Class-1 pedal-assist bicycles on off-road natural surface trails where appropriate. We ask the DCR to not enact their proposed statewide prohibitions without proper analysis of impact.
- DCR should use studies and research, including crash data and wear on terrain, when determining where differing classes of electric bicycles should and shouldn't ride, especially for off-road natural surface trails and for the bikeway and multi-use paths.
You can learn more about the 3 class system, and how these bikes are categorized here.
We're asking you to speak up and join us! See the script below for you to use when sending in your comments to the DCR. The deadline for public comment is Wednesday July 24 at 5pm.
If you have any questions about this comment period or about e-bikes in general, please e-mail us. To read more information on our e-bike legislation read here.
SAMPLE SCRIPT FOR DCR COMMENTS
If sending via e-mail, please send to:
I am writing in opposition to 302 CMR 11.00: Parkways, Traffic, and Pedestrian Rules 302 CMR 12.00: Parks and Recreation Rules, which would prohibit usage of electric bicycles on all natural surface trails, improved trails that are less than 8’ wide and on dirt roads that are not open to vehicular traffic.
I would ask that in order to provide clarity on exactly the devices being regulated, the DCR should follow the 3-class model system that defines the types of electric bicycles being regulated, or hold off until legislation is passed by the state that would create a classification system in Massachusetts.
I also ask that the DCR look to allow Class-2 and Class-3 electric bikes where appropriate on paths and roadways, and that the DCR should look to allow Class-1 electric bicycles on off-road natural surface trails where appropriate. I ask that the DCR to not enact any statewide prohibitions without proper analysis of the impact and encourage the use of studies and research in determining where differing classes of electric bicycles should and shouldn't ride, especially for off-road natural surface trails and for the bikeway and multi-use paths.
[Talk about why this issue matters to you.]
Thank you for considering the important role that e-bike play in our state.
city/town, state, zip
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