HomeMy WebLinkAbout081325-Correspondence (2)Danville Safety Advocates
Staff Report
July 28, 2025
To: Asha Weinstein Agrawal, PhD, Director of Education, Mineta Transportation Institute, San
Jose State University
Subject: “Exploring E-Bike Safety Performance Data and Policy Options”
Introduction
The rapid rise of electric bicycles—particularly throttle-operated models often mislabeled as
Class 2 “e-bikes,”—here termed e-motos, has introduced a new and urgent set of safety
challenges across California. Designed and marketed as accessible, fun, and eco-friendly
alternatives to traditional bicycles, e-motos are in fact powerful electric motorcycles capable of
reaching speeds of 40 miles per hour and higher. Increasingly, they are being operated by middle
school-aged children with little to no training, supervision, or understanding of the risks
involved. (photo below: E-Motos Parked in the Bicycle Corral at Diablo Vista Middle School,
Danville CA)
This report, prepared by the Danville Safety Advocates, explores the real-world safety risks these
devices pose to riders and the public—especially when used by children. Drawing on community
observations, public records, and emerging policy research, the report highlights alarming gaps
in crash data, enforcement, and regulation. It also offers practical, enforceable policy
recommendations for local and state officials—including new rules of the road, design standards,
public education initiatives, and statewide legislative reforms. The stakes are high. Without
immediate and coordinated action, California’s most vulnerable road and trail users—including
children, pedestrians, seniors, and cyclists—remain at unacceptable risk. Staff Report:
Over 200 "E-Motos" at Local Middle Schools
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1. What risks do e-bikes pose to riders and to other (e.g. pedestrians,
motorists, other cyclists)?
Throttle-operated electric bikes (“E-Motos”), especially those falsely labeled as Class 2 e-
bikes, present significant dangers particularly when used by children ages 11–15. These are
not toys. These are powerful electric motorcycles disguised as bikes.
1. Excessive Speed
Many e-motos reach 28–40+ mph—far exceeding the speed of human-powered bicycles.
Young riders often lack the judgment, coordination, and reflexes to handle such velocity,
let alone understanding the rules of the road, placing themselves and others at serious
risk.
2. High Momentum and Weight
Weighing up to 100 pounds, e-motos are difficult for children to maneuver or stop. In a
collision, the momentum of these machines can cause devastating injuries to:
a) Pedestrians, especially seniors and young children
b) Other cyclists sharing narrow lanes, paths, or trails
c) Motorists, who may not anticipate the speed or erratic behavior of young e-moto
riders in intersections and crosswalks
3. Throttle-Based Acceleration
Unlike pedal-assist bikes, e-motos use a twist throttle—launching the vehicle instantly.
Children often use them like toys, leading to:
a) Jerky, uncoordinated starts
b) Sudden speed bursts into traffic
c) Frequent loss of control
4. Reckless Stunt Behavior
Many young riders perform wheelies, jumps, and other stunts—often on sidewalks,
trails, and park pathways used by pedestrians and cyclists. This recklessness
significantly increases the chance of traumatic injuries.
5. Modification Hazards
Throttle-based bikes are easily hacked using apps or after-market kits, removing speed
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and power limits. These illegal modifications turn already-dangerous e-motos into
unregulated electric motorcycles, operating at speeds well above the legal limit—with
no license, insurance, or training. Watch the Public Service Announcements
6. Brake Failure and Poor Maintenance
Many e-motos sold online or in big-box stores lack reliable components. Brakes often go
unmaintained, especially when used by children. Worn or ineffective brakes lead to:
a) Extended stopping distances
b) Higher-speed collisions
c) Greater injury severity to both riders and others
7. Improper Fit for Children
Most e-motos are built for adult riders. When used by children, the oversized frames and
improper ergonomics result in:
a) Poor posture and reduced control
b) Increased risk of joint injuries
c) Greater instability during falls or abrupt maneuvers
(photo above: 70 “E-Motos” Parked in the Bicycle Corral at Stone Valley Middle School)
Conclusion: E-Moto use by children is a public safety crisis in the making. The proliferation of
throttle-operated electric bikes—often falsely marketed as Class 2 e-bikes—poses a clear and
escalating danger, particularly when used by middle-school-aged children. These devices are, in
reality, powerful electric motorcycles. They are capable of speeds, weights, and accelerations far
beyond what a young, unlicensed, and inexperienced rider can safely manage.
The combination of excessive speed, high momentum, throttle-based acceleration, and poor
braking systems significantly increases the likelihood of severe injuries—not just to the rider, but
to everyone around them. Pedestrians, particularly seniors and small children, are at the greatest
risk in shared spaces like sidewalks, trails, and parks. Other cyclists are placed in jeopardy on
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narrow paths. Even motorists face unpredictable hazards when young e-moto riders dart into
intersections or swerve across traffic lanes.
The situation is further exacerbated by widespread device modification, inadequate maintenance,
and a lack of regulatory enforcement. When children ride machines that are too large, too fast,
and too dangerous for their size and skills, the consequences are entirely predictable—and
preventable. Without immediate legislative action, stricter enforcement, and public education,
injuries will increase. Tragedies are not a matter of “if,” but “when.” It is time to treat this issue
with the urgency it demands. These are not bikes. They are unlicensed motor vehicles—and
should be regulated, labeled, and restricted as such. Watch the Slide Show - These are NOT
Bicycles, they are Electric Motorcycles
2. Is current crash and injury data sufficient to understand these safety risks?
(photo above: E-moto – Vehicle Collison, Danville, CA)
No. The current crash and injury data environment is deeply flawed and fails to provide a clear
or accurate picture of the safety risks associated with e-bikes and e-motos—especially for
children. Here’s why:
1. Underreporting in OTS and SWITRS Systems
• OTS (Office of Traffic Safety) and SWITRS (Statewide Integrated Traffic
Records System) data suggest few or no e-bike or e-moto incidents in places like
Danville, let alone significant underreporting of all collisions. This is misleading.
• The reality on the ground—observed by parents, schools, first responders, and
community safety advocates—shows daily near-misses, injuries, and collisions
involving throttle-operated electric bikes.
• This discrepancy indicates systemic underreporting or misclassification of crash types
in official records. E-Moto Injuries in Danville
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2. Why it matters: Policy decisions and funding rely heavily on these databases. Inaccurate
data = inaction = increased risk.
No Designated E-Bike Field in Local Reporting Tools
• Danville’s Crossroads collision reporting system (used by law enforcement) does
not include a dedicated field to indicate whether a crash involved an electric bike,
electric motorcycle, or traditional bicycle.
• Officers are often left to manually describe incidents, meaning critical details about
throttle use, top speeds, or vehicle class may be omitted or misrepresented.
• Result: E-moto crashes often get lumped in with traditional bike or vehicle crashes,
masking the serious risks these devices present.
3. Public Records Are Difficult to Access
• Accessing full crash details typically requires filing a Public Records Act (PRA)
request, a burdensome and time-consuming process.
• When records are released, they are often scanned PDFs with no searchable text,
making analysis, aggregation, or comparison nearly impossible without hours of
manual review.
• There is no public-facing dashboard for real-time reporting or community
awareness.
4. Systemic Failures at the State Level
• Even if crash data is being collected at the local level, it is not flowing accurately or
consistently to state agencies.
• There is no standardized classification system to differentiate throttle-powered e-
motos from pedal-assist e-bikes, mopeds, or even scooters.
• The result is a statewide data blind spot that undermines public safety planning and
makes it extremely difficult to quantify:
o The frequency of e-moto-related injuries
o Who is getting injured (e.g., children under 16)
o Where these crashes are happening (e.g., sidewalks, trails, parks,
intersections)
Conclusion: The existing crash and injury data systems—locally in Danville and statewide in
California—are grossly insufficient to accurately assess the safety risks posed by e-bikes and
throttle-operated electric motorcycles (e-motos). The lack of standardized classification, chronic
underreporting, and barriers to public data access have created a dangerous blind spot in public
safety awareness and response. Despite daily near-misses, injuries, and collisions observed by
residents, parents, schools, and first responders, official databases such as SWITRS and
Crossroads fail to reflect the true scope of the problem.
Without dedicated fields for electric vehicles and without a uniform, statewide system to track e-
moto-specific incidents, policymakers are left making decisions in the dark. This data failure
delays critical infrastructure upgrades, enforcement, and policy reform—and most alarmingly, it
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leaves children, pedestrians, and cyclists at increasing risk. We cannot fix what we do not
measure. Until local, county, and state agencies overhaul their reporting systems and adopt
transparent, real-time data tools, the full extent of the e-moto safety crisis will remain
obscured—and lives will remain at risk.
3. What should be the “rules of the road” for riding e-bikes, particularly with
respect to speed, age limits, and infrastructure usage?
As electric mobility devices rapidly proliferate—particularly throttle-operated e-bikes (“e-
motos”)—California must establish uniform, enforceable statewide rules that protect children,
pedestrians, cyclists, and all road users. This framework outlines essential standards regarding
age, speed, infrastructure usage, and law enforcement practices.
Age Restrictions: Prohibit Throttle Use by Children Under 16
1. Riders under age 16 should be prohibited by law from operating any electric bicycle
with a throttle or capable of exceeding 20 mph, including Class 2 and Class 3 e-bikes.
2. E-Motos operate more like electric motorcycles than bicycles and are often involved in
high-severity crashes involving youth.
3. Enforcement Across California:
a) Peace officers statewide (CHP, sheriffs, local police) should be authorized to:
i) Issue citations or confiscate devices operated illegally by underage users.
ii) Issue parental warnings and liability notices, referencing CVC §14604
(unlicensed driver operation) and Penal Code §273a (child endangerment).
iii) Refer families to educational diversion programs where available.
Prohibit E-Bikes from sidewalks, Park paths and Grassy recreational areas
• E-Bikes should be banned from:
o Sidewalks
o Park paths and grassy recreation areas
• These are spaces primarily designed for vulnerable users: seniors, families, pedestrians
with disabilities, and young children.
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• State Enforcement Guidance:
o CHP and local departments should conduct spot enforcement operations on
high-use trails and sidewalks.
o Consider state-level grant funding for signage and patrols under the California
Office of Traffic Safety.
Regulate Use of Bike Lanes Based on Speed
• E-motos should only operate in designated bike lanes if traveling at or below 20 mph.
• Devices exceeding that speed must merge into general traffic and follow motor vehicle
laws under CVC §21207.5.
• Statewide Enforcement:
o Local agencies should implement portable radar units to conduct speed
enforcement in bike lanes and issue citations.
o Use progressive ticketing: warnings for minor first-time violations, citations for
repeat or dangerous riders.
Police Education and Tiered Enforcement
• Mandatory POST training for all law enforcement officers on:
o E-bike classification (Class 1, 2, 3 vs. e-motos, mopeds)
o Relevant codes (CVC §§ 24016, 21213, 406(b))
o Safe enforcement practices with youth riders
• Encourage agencies to adopt a tiered citation system:
o Tier 1 – First-time: verbal/written warning
o Tier 2 – Formal citation, safety class required
o Tier 3 – Citation + possible equipment confiscation for egregious or repeat
offenses
Statewide Data Transparency and Accountability
• Require local and state law enforcement to:
o Track and report citations and warnings related to e-bike/e-moto violations by
age, location, and severity.
o Submit monthly data to OTS for statewide dashboard publication.
• Expand SWITRS (Statewide Integrated Traffic Records System) to include:
o Specific fields for e-bike class, throttle usage, and rider age
o Trail, park, and sidewalk-specific incident flags
Public Awareness and Parental Accountability
• Launch a California-wide public safety campaign:
o "Throttle = Motorcycle" or “Not a Toy, Not a Bike”
o Distribute to schools, DMVs, pediatricians, retailers, and digital platforms
• Partner with schools and parks to:
o Offer safety training and permitting for youth riders
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o Post clear signage at trail and park entries: “No E-Motos—Walk Your Bike or
Face Citation”
• Clarify civil and criminal parental liability for injuries caused by illegally operated e-
motos.
• State registration of Class 2 &3 electric bicycles with the requirement to display
identification on the rear of the device, similar to motorcycles.
Conclusion: A unified statewide approach is urgently needed. The rapid rise of throttle-
operated e-bikes and high-powered electric mobility devices has outpaced California’s
current traffic laws and infrastructure. Left unregulated, these vehicles—often ridden by
children under 16—pose serious and growing threats to pedestrians, cyclists, motorists, and
the young riders themselves. Local ordinances or county by county exceptions cannot
address this crisis. The current fragmented patchwork of enforcement and policy leaves
communities vulnerable and creates confusion among families, law enforcement, and
retailers.
California must implement a unified, enforceable statewide policy framework that prioritizes
public safety, especially for children and vulnerable road users. This includes age restrictions
for throttle-equipped e-bikes, clear bans on their use in places like sidewalks, parks, and
pedestrian trails, and speed regulations tied to appropriate infrastructure access. It also
demands the installation of physical deterrents in high-risk areas, consistent officer training
and enforcement, statewide data tracking, and a strong public education campaign focused on
both youth and parents. Without bold and coordinated action, near-miss collisions, injuries,
and fatalities will only increase. A modern, evidence-based approach is essential to ensure
that electric mobility remains a safe and sustainable part of California’s transportation
future—not a public safety liability.
4. What standards or requirement should apply to the design and
characteristics of e-bike devices themselves (e.g., speed limits, throttle control,
labeling)?
1. Tamper-Proof Design – If an e-bike can be modified to exceed 20 mph or 750W, it does
not legally qualify as a Class 2.
2. Mandatory Registration – Require DMV registration and license plates for all throttle-
operated devices, especially those capable of exceeding legal limits.
3. Truth in Labeling – Stronger laws are needed to prevent deceptive Class 2 labeling of
electric motorcycles.
4. Warning Labels – Require clear warnings: “Helmet Required. Riders Must Be 16 or
Older. This is Not a Bicycle.”
Conclusion: Design standards must align with safety and truth in marketing. The physical design
and labeling of electric mobility devices play a critical role in user behavior, risk perception, and
public safety. As it stands, many throttle-operated vehicles are deceptively marketed as “Class 2
e-bikes” despite their ability to reach dangerous speeds and power outputs that far exceed legal
limits. This loophole has allowed electric motorcycles to bypass essential safety regulations—
putting children, pedestrians, and other road users in harm’s way. To protect the public and
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restore regulatory clarity, California must adopt enforceable design and labeling standards. E-
bikes should not be modifiable beyond 20 mph or 750 watts—and any product capable of
doing so should be reclassified and regulated accordingly. The current law should be enforced.
Mandatory DMV registration and license plates for high-powered throttle-operated devices
will help law enforcement distinguish legal from illegal vehicles in real time.
Furthermore, truthful product labeling and clear safety warnings are essential to prevent
parents from unknowingly purchasing unsafe vehicles for children. Without these reforms, the
marketplace will remain flooded with misbranded electric motorcycles masquerading as
bicycles. Stronger design, registration, and labeling requirements are not only common sense—
they are the foundation of a safe and trustworthy e-mobility ecosystem. Danville Safety
Advocates urge state policymakers, regulators, and researchers to prioritize these standards as
part of any comprehensive e-bike safety legislation.
5. Beyond rider regulations, what state-level policies could help promote safe
e-bike use (e.g., public education, licensing, insurance, product safety
standards)?
1. Amend the California Vehicle Code – Prohibit anyone under 16 from operating Class 2
throttle-assisted e-bikes.
2. Launch Statewide Education Campaigns – Target middle school parents with clear
messaging about liability, safety risks, and crash statistics. Parents Get the Facts Before
Buying Your Child a Class 2, Throttle-Assisted Electric Motorcycle "E-Moto"
3. Create a State Registration System – for Class 2 and Class 3 e-bikes - Include
insurance, VIN tracking, and theft prevention.
4. Prohibit Mislabeling – Penalize companies that market motorcycles as “e-bikes.”
5. Require Rider Training – E-moto riders should be required to complete a basic
motorcycle safety course. What Every Kid Should Know Before Riding a Class 2 "E-
Moto"
Conclusion: State-level leadership is essential for safe e-bike use. Ensuring the safe
integration of e-bikes and throttle-assisted devices into California’s transportation ecosystem
requires more than just rider restrictions—it demands bold, statewide policy leadership. The
growing presence of high-powered e-mobility vehicles, especially among youth, underscores
the urgent need for legislative and regulatory action. Amending the California Vehicle Code
to prohibit underage throttle use would close a dangerous legal loophole and align the law
with known developmental safety risks. A well-funded statewide education campaign—
targeted at middle school families—could dispel misinformation, highlight legal liabilities,
and provide lifesaving awareness around injury trends and crash dynamics.
Establishing a centralized state registration system, complete with VIN tracking, insurance
requirements, and theft prevention protocols, would legitimize ownership while improving
accountability and enforcement. The state must also crack down on deceptive product
labeling. Marketing electric motorcycles as “Class 2 e-bikes” undermines public safety and
misleads parents into purchasing high-risk vehicles for children. Finally, requiring basic rider
training—especially for those operating throttle-assisted devices—would ensure that users
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have the skills and judgment necessary to ride responsibly. California has an opportunity to
lead the nation in safe, responsible e-mobility policy. That leadership begins with clear laws,
public education, and consumer protections that match the speed and power of the devices
they govern.
Final Conclusion: A Call for Statewide Partnership and Immediate Action
The findings in this report point to an undeniable public safety crisis: the unregulated
proliferation of throttle-operated electric motorcycles—many disguised as Class 2 e-bikes—is
placing children, pedestrians, and cyclists at unacceptable risk. The data gaps, lack of
enforcement, imprecise laws and regulation, and misleading product labeling create a perfect
storm of injury, confusion, and inaction. Without a coordinated statewide approach, these risks
will only continue to escalate.
We believe this challenge cannot be solved by local advocacy alone. It demands leadership,
collaboration, and innovation across state agencies, counties, municipalities, academic
institutions, and community-based organizations.
Danville Safety Advocates look forward to working with the Mineta Transportation Institute to
further research these issues, develop statewide best practices, and advance legislative reforms
grounded in data and equity. Together, we can design comprehensive policy frameworks that
prioritize safety without compromising the promise of sustainable electric mobility.
Prepared by the Danville Safety Advocates Leadership Team
Alan Kalin, Bruce Bilodeau, Jeff Eorio, Todd Gary, Jim Berriatua, Bob Mittelstradt, Nicola
Place and Kyle Smith
For more information visit Danville Safety Advocates
Attachments:
E-Moto Safety Assessment San Ramon Valley Middle Schools (June 10, 2025)
E-Moto & E-Scooter Survey at Local Middle Schools (Feb 24/25, 2025)