Coalition Comments on Use of Electric Bicycles within the National Park System

 

July 14, 2023

Electric Bicycle Programmatic EA
National Park Service
1849 C Street NW, MS-2472
Washington, DC 20240

Subject:  Programmatic EA – Use of Electric Bicycles within the National Park System

Dear National Park Service:

I am writing on behalf of the Coalition to Protect America’s National Parks, which represents over 2,400 current, former, and retired employees and volunteers of the National Park Service (NPS). Collectively, our membership represents over 45,000 years of national park management and stewardship experience. Our membership includes former NPS directors, deputy directors, regional directors, and park superintendents. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related NPS programs.

We offer the following comments on the programmatic environmental assessment (PEA) for the use of electric bicycles (e-bikes) within units of the National Park System (parks).

BACKGROUND

The following information is gleaned from multiple sources that NPS is undoubtedly familiar with. We provide this summary here as context for our comments on the PEA:

On August 29, 2019, the Secretary of the Interior issued Secretarial Order No. 3376 (SO) on the subject of “Increasing Recreational Opportunities through the use of Electric Bikes” and the next day Acting NPS Director P. Daniel Smith issued NPS Policy Memorandum 19-01 (the Smith Directive). The latter document directed park superintendents to use their respective compendiums to “allow e-bikes where traditional bikes are allowed” and “not allow e-bikes where traditional bikes are prohibited, including in wilderness areas.” It also advised that the compendium action would ordinarily fall within the categorical exclusion (CE) that is specified in section 3.3.D.3 of the NPS NEPA Handbook 2015 for which documentation is required. CE 3.3.D.3 applies to: “Minor changes in programs and regulations pertaining to visitor activities.” 

 When the SO and the Smith Directive were issued, NPS regulations at 36 CFR §1.4 defined “Bicycle” as “every device propelled solely by human power upon which a person or persons may ride on land, having one, two, or more wheels, except a manual wheelchair.” (Emphasis added)  Similarly, NPS regulations at 36 CFR §1.4 defined “Motor vehicle” as “every vehicle that is self-propelled and every vehicle that is propelled by electric power, but not operated on rails or upon water, except a snowmobile and a motorized wheelchair.” (Emphasis added) In other words, at the time of the SO and the Smith Directive, e-bikes clearly did not meet the NPS definition of “bicycle” since e-bikes are not “propelled solely by human power”; and e-bikes clearly met the NPS definition of “motor vehicle” in effect at that time. As a result, NPS should not have allowed e-bikes on any administrative roads and trails that were closed to “motor vehicles” prior to NPS rulemaking to change the applicable definition(s). However, scores of parks allowed e-bike use anyway based on the Smith Directive.

Public Employees for Environmental Responsibility (PEER) and other groups and individuals filed a lawsuit in U.S. District Court alleging that NPS had violated multiple federal laws in authorizing widespread e-bike use based on the Smith Directive. The NPS subsequently issued a proposed rule on e-bike use on April 8, 2020, which was followed by issuance of a final rule on November 2, 2020. The final rule created a new definition for the term “electric bicycle,” specifically excluded “electric bicycles” from the definition of “motor vehicle,” and established regulations governing the use of e-bikes within units of the National Park System. The rule placed the burden on individual park superintendents to conduct a NEPA review before allowing e-bike use on a park’s administrative vie roads and trails. In the Response to Comments section of the preamble to the final rule, NPS also stated that the impacts of e-bike use “would be at the park level, not at a national scale. Therefore… the NPS does not believe a programmatic NEPA review is warranted.”

On June 30, 2021, NPS Deputy Director Shawn Benge issued a Memorandum (the Benge Memorandum) directing superintendents to review, in light of the final rule, their previous approval(s) of e-bike use implemented in respective park compendiums under the Smith Directive. Similar to the final rule, the Benge Memorandum placed the burden on individual park superintendents to “comply with NEPA and [] either document why a categorical exclusion is appropriate or conduct an environmental assessment if appropriate.” Similar to the Smith Directive, the Benge Memorandum advised superintendents that “compendium actions regarding changes to or the recertification of e-bike use on trails or administrative roads may fall within the categorical exclusion (CE) for ‘minor changes in programs and regulations pertaining to visitor activities’ specified in section 3.3.D.3 of the NPS NEPA Handbook.”

On May 24, 2022, the U.S. District Court for the District of Columbia issued a ruling in PEER v. NPS. According to the Court’s Memorandum Opinion, prior to the 2020 NPS rulemaking “380 park units had already implemented the Smith Directive’s e-bike policy” in allowing e-bike use presumably following the directive’s CE recommendation (see footnote # 18 on p. 48). The Memorandum Opinion also noted that in response to the Benge Memorandum about 136 parks prepared CE forms to document and re-certify their previous decisions to allow e-bike use on park administrative roads and trails, while “at least six parks made substantive changes” to their respective e-bike policies (see p. 6).

The Court’s Memorandum Opinion, pp. 44-45, also describes the fallacy of the NPS explanation of how parks conducted NEPA compliance: “The vast majority of the park units…took the Smith Directive’s invitation to invoke Categorical Exclusion 3.3.D.3 from the NEPA Handbook, determining that the allowance of e-bikes would be only a minor change to visitor activities… For the most part, the [individual park] Categorical Exclusion documentation suggests that the park superintendents relied heavily on the Smith Directive when determining that e-bikes would not have significant impacts… Basically, the Smith Directive attempted to avoid conducting any environmental analysis because the park units would do so, and the park units in turn largely declined to conduct additional analysis because the Smith Directive had already suggested that the change was minimal… By relying on the fact that NEPA analysis that had already been ‘required’ by the Smith Directive, and those parks’ determination that a Categorical Exclusion applied, the Final Rule ‘used [the Smith Directive] as a false justification for a continuing NEPA violation.’” (Emphasis added)

The Court concluded that the final rule preserved and relied on the Smith Directive’s arbitrary and capricious use of CE 3.3.D.3 in the NPS NEPA Handbook. Then, in response to the Benge Memorandum, the vast majority of parks that had previously invoked CE 3.3.D.3 under the Smith Directive did so again under the Benge Memorandum. As a result, the Court ordered NPS “to determine the proper level of NEPA compliance for the Final Rule, adequately document its reasoning, and provide opportunity for public input as appropriate.” See Memorandum Opinion, p. 51.

In other words, the Court has directed the NPS to determine and prepare the “proper level” of NEPA compliance; it did NOT direct NPS to specifically prepare a PEA. And, given NPS’s previously stated belief that the impacts of e-bike use “would be at the park level, not at a national scale [and] a programmatic NEPA review would not be warranted” (see preamble to the final rule), it is perplexing that NPS has decided to prepare a PEA now.

The final rule and the subsequent Benge Memorandum clearly placed the burden on individual park superintendents to conduct and document NEPA compliance at the park level if/when a park chooses to allow e-bike use on administrative roads and trails. Presumably, many of the approximately 136 parks that have allowed e-bike use on administrative roads and trails since the issuance of the Smith Directive have continued to rely on the CE found in section 3.3.D.3 of the NPS NEPA Handbook. The CE applies to “minor changes in programs and regulations pertaining to visitor activities.” Although the Benge Memorandum specifically required “superintendents must upload a link to the updated compendium language, the signed CE, and any associated documentation to PEPC,” we are not aware of any parks making such information available to the public on the park’s PEPC website.

 GENERAL COMMENTS 

1. First, we appreciate the opportunity to comment on the NPS programmatic environmental assessment (PEA) of potential environmental impacts of the use of e-bikes in national park units – The recent (i.e., 2019) “authorization” of e-bike use in parks has had a problematic procedural and environmental compliance history that is summarized above as well as in Section 1.1 of the PEA. In brief, since 2019, the vast majority of parks that have allowed e-bike use on administrative roads and trails have done so under CE documentation that has never been made available to the public. As a result, there have been very few opportunities for the public to comment on any NPS analysis of potential environmental impacts of the use of e-bikes in national park units. It is disappointing that the current opportunity for comment has resulted only because of litigation. PEER v. NPS, 605 F. Supp. 3d 28 (D.D.C. 2022). However, we do appreciate the opportunity to comment now.
2. The PEA does not resolve ongoing concerns about the adequacy of park-specific NEPA compliance to support the many compendium decisions allowing e-bike use in parks –After the issuance of the Smith Directive, numerous parks reportedly followed the Directive’s recommendation that parks cite categorical exclusion (CE) 3.3.D.3 in the NPS NEPA Handbook. After the final rule was issued, the Benge Memorandum directed parks to re-visit and re-certify their previous decision(s) to allow e-bike use; but also recommended that parks consider citing CE 3.3.D.3 as the NEPA compliance for allowing such use. As a result, there is no compelling evidence that the NPS or the many parks that have allowed e-bike use have ever taken a legitimate “hard look” at the distinct differences between e-bikes and traditional bicycles and the potential impacts that could result from those differences.

In contrast to NPS’s approach with this PEA, many federal agencies utilize programmatic NEPA reviews to evaluate not only the environmental effects of a proposed activity (e.g., in this case e-bike use), but also to identify and evaluate the effectiveness of potential guidelines and methodologies associated with management of the particular activity. The resulting programmatic NEPA documents typically provide useful guidance, such as a suite of recommended mitigation measures and/or best management practices, for local site managers to consider when deciding how to manage the activity at the local level. However, NPS has not done so in this case, which strikes us as a missed opportunity for NPS to turn the Court-ordered NEPA review into information and guidance that is useful to parks.

To address our concern about the absence of visible NEPA documentation for the 136 or so parks that have allowed e-bike use on administrative roads and trails, we recommend that NPS do the following:

1) Add an appendix to the PEA that identifies all 136 parks (or whatever the correct number is) that have allowed e-bike use on administrative roads and trails; and also identifies the level of NEPA documentation, such as a CE or EA, that was prepared by each park in support of their respective decision;

2) Have individual parks or regions prepare a “memorandum to the file” to document NEPA adequacy for those parks allowing e-bike use on administrative roads and trails;

3) Have all such parks post their NEPA documentation, whatever it is, on their respective PEPC websites in a manner that the information is accessible to the general public (e.g., create a project page titled something like “Electric bicycle environmental review” and post the document(s) there); and

4) The PEA should include a description of the change(s) in circumstances or conditions that would trigger a fresh park-level NEPA review regarding e-bike use.

SECTION-BY-SECTION COMMENTS

Chapter 1: Purpose, Need, and Issues Analyzed 

1. Section 1.2 Purpose and Need for Taking Action – Since NPS considers e-bikes to be an “emerging form of recreation” that is relatively new to parks, it would have been appropriate for ALL park-specific NEPA reviews to include an “appropriate use analysis” consistent with NPS Management Policies 2006, Section 1.5, which states: “A new form of park use may be allowed within a park only after a determination has been made in the professional judgment of the superintendent that it will not result in unacceptable impacts.” (Emphasis added) However, since few, if any, park-specific e-bike NEPA documents have been available to the public, it is unclear to what extent parks have complied with this NPS management policy requirement. Such information should be included in each park’s NEPA compliance document. As part of the programmatic review, NPS should review and verify individual park compliance with Management Policy Section 1.5.

Chapter 2: Alternatives 

1. Section 2.1 Alternative 1: No Action – Regarding the choice of pre-2019 conditions as the No Action Alternative, we understand the dilemma of trying to identify a legitimate No Action Alternative in situations where the Court has ordered an agency to retroactively prepare a NEPA review for action(s) the agency has already implemented. In this case, the irony is that the No Action Alternative (“return to the status quo prior to the 2019 policy and the 2020 rule”) is the only alternative that would require actual “action” on NPS’s part, since NPS would have to actively “undo” the change in policy and the subsequent rulemaking.

What the NPS description of the No Action Alternative fails to acknowledge is that prior to the 2020 Final Rule, then-existing NPS regulations at 36 CFR §1.4 defined the following terms: “Bicycle means every device propelled solely by human power upon which a person or persons may ride on land, having one, two, or more wheels, except a manual wheelchair.” (Emphasis added)“Motor vehicle means every vehicle that is self-propelled and every vehicle that is propelled by electric power but not operated on rails or upon water, except a snowmobile and a motorized wheelchair.” (Emphasis added), In other words, prior to the 2020 rule e-bikes were NOT considered the same as “bicycles” under NPS regulations, but clearly met the definition of a “motor vehicle.” Therefore, e-bikes could NOT have been legally allowed on any administrative roads and trails that were closed to motor vehicles but open to traditional bicycles.

As a result, it would be more accurate for NPS to describe the No Action Alternative in the PEA along the lines of the following: “Under this alternative, if NPS were to undo the 2020 rulemaking, including removing the definition of ‘electric bicycles,’ then e-bikes would revert to meeting the definition of ‘motor vehicle’ and could not be legally authorized on administrative roads and trails that are otherwise closed to motor vehicles.” In essence, the No Action Alternative should be described as the “no e-bikes alternative.” We ask NPS to correct the PEA as described above. As this section is currently written, it creates the misleading impression that the primary consequence of NPS “undoing” the final rule would simply be inconsistent management of e-bikes in parks when, in reality, e-bikes would not be legal to use on park administrative roads and trails.

2. Section 2.2 Alternative 2: Proposed Action (Preferred Alternative) – As described in the PEA, “[u]nder the proposed action, the NPS would implement the 2020 rule, which gives superintendents discretionary authority to allow the use of e-bikes, or classes of e-bikes, on a case-by-case basis, on park roads, parking areas, administrative roads, and trails that are otherwise open to traditional bicycle use… The rule allows superintendents to manage e-bikes, or particular classes of e-bikes, differently [i.e., more restrictively] than traditional bicycles in certain locations, as warranted.” (Emphasis added)

In general, we support the core concept of the Preferred Alternative, which is that park superintendents should have the discretionary authority to determine the appropriateness of allowing or prohibiting e-bike use, including on administrative roads and trails, and to establish safety measures or other requirements within a given park. Our primary concern is that the vast majority of parks allowing e-bike use today initiated such use under the false justification of the Smith Directive; and NPS has provided little public evidence since then that those parks have taken a legitimate “hard look” at the potential impacts of such use.

We therefore suggest the Preferred Alternative include the following provisions:

a) Parks (or regions) will prepare a” memorandum to the file” to document NEPA adequacy for those parks allowing e-bike use on administrative roads and trails;

b) Parks allowing e-bike use on administrative roads or trails will post their NEPA documentation, whatever it is, on their respective PEPC websites in a manner that the information is accessible to the general public (e.g., create a project page titled something like “Electric bicycle environmental review” and post the document(s) there);

c) A description of the change(s) in circumstances or conditions that would trigger parks to conduct a fresh park-level NEPA review regarding e-bike use; and

d) A list of established mitigation measures and best management practices (BMPs) for limiting impacts associated with e-bike use, especially those impacts that may result from the distinct difference in speed capability between e-bikes and traditional bicycles.

Chapter 3: Affect Environment and Environmental Consequences

1. Section 3.2.1 Scope of the Analysis – As described in the document: “This PEA analyzes the potential programmatic national-level impacts that could occur as a result of implementing the proposed action.”

A component of “scope” that should be considered in the analysis is how many parks may be affected by the proposed action. Various planning and court documents have identified differing numbers of parks that have allowed e-bike use on administrative roads and trails since the issuance of the Smith Directive. As a result, it is unclear how many or which parks were affected by the 2020 rulemaking and should now be considered in the PEA’s impact analysis about that rulemaking. We ask again that NPS provide, as an appendix to the PEA, an accurate and complete list of all parks allowing e-bike use on administrative roads and trails; and the level of NEPA compliance (e.g., CE, EA, or EIS) that each of those parks prepared in support of their respective e-bike decisions.

2. Section 3.2.2 Mitigation – This section of the PEA emphasizes the importance of using “sustainable design” when developing bicycle trails. However, it is unclear from the description what constitutes “sustainable design” when it comes to bicycle trails. We strongly recommend that NPS broaden its focus beyond “sustainable design” and provide a more comprehensive list of practical mitigation measures and best management practices (BMPs) that superintendents can consider when determining how to manage e-bike use on any particular trail. For example, there should be a list of measures for limiting the potential conflicts and impacts that may result from the distinct difference in speed capability between e-bikes and traditional bicycles. In addition, the BMPs could include compliance with recommended sustainable design guidelines when upgrading existing bike trails or constructing new bike trail. And the BMPs should also include close coordination with neighboring federal land management jurisdictions, such as the Bureau of Land Management and the U.S. Forest Service when appropriate, when those agencies are dealing with e-bike management on their administrative roads and trails adjacent to parklands.

In addition to “sustainable design,” NPS should identify conformance with safe design standards as a BMP in the PEA. We strongly recommend that NPS adopt the widely accepted American Association of State Highway Transportation Officials (AASHTO) Guide for the Development of Bicycle Facilities as the service-wide bicycle trail and shared use path design guidelines. For example, the AASHTO guide recommends that the paved tread on shared use paths should be at least 10 feet wide, with a graded shoulder at least 2 feet wide on either side of the path. On shared use paths with heavy volumes of users, tread width should be increased to a range from 12 feet to 14 feet. In addition, shared use paths should not exceed a grade of 5%.

Our observation is that only recently built NPS shared use paths may meet AASHTO safety standards; and most shared use trails in parks that we are familiar with pre-date and do not meet such standards. We are particularly concerned that parks have been allowing e-bike use on shared use trails apparently without conducting a systematic evaluation of the adequacy of NPS bicycle trail facilities to determine if they are designed to safely accommodate the proposed use. E-bikes should NOT be authorized on shared use paths that do not meet appropriate safety guidelines.

3. Section 3.2.3 Organization of This Chapter – As described in this section, Chapter 3 is organized by impact topics. Most of the impact topics analyzed describe the impacts of e-bikes as being similar to that of traditional bicycles. For example, both kinds of bicycles may impact soils, vegetation, and wildlife in similar fashion. We concur with that assessment and we will focus our comments below on the impact topic in which we think the NPS analysis has not adequately described or evaluated the impacts of the differences between e-bikes and traditional bicycles.
4. Section 3.5.1 Affected Environment – Visitor Use and Experience – The analysis in this section, as well in Sections 3.5.2 (No Action) and 3.5.3 (Proposed Action) does not adequately describe the implications of the most obvious and significant difference between e-bikes and traditional bicycles, which is the difference in speed capability. In general, much of the PEA analysis of potential conflicts between e-bike users and other trail users suggests that such conflicts “result from differences in activity ‘styles’ and associated perceptions” (i.e., subjective perceptions), rather than from the very real difference in speed capability. In creating its analysis narrative about those similarities, NPS cites a relatively limited number of studies that generally downplay the significance of the differences in speed capability, and as a result NPS fails to describe or fully consider the well-documented impacts of those differences (e.g., higher accident rates and more serious accident outcomes for e-bike users).

In contrast, we can cite numerous studies, article, and advertisements that describe the significant differences in speed capability between e-bikes and traditional bicycles. For example, multiple sources indicate that “e-bikes are capable of reaching speeds of up to 20 miles per hour (or 28 mph for class 3 models), while most regular bikes top out at around 10 miles per hour for beginners or 15 mph for intermediate riders.” Other studies document the reality that e-bikers typically ride faster than traditional bicyclists, which is acknowledged by e-bike riders themselves. For example, a 2018 study (MacArthur, Cherry, Harpool and Scheppke)found that “68.5% of [e-bike rider] respondents agree or strongly agree that they go faster than other [traditional] cyclists, while 81.6% agree or strongly agree that, on average, they go faster than they would on a standard bicycle. In regards to safety, the speed of the e-bike is a more complicated aspect. Some respondents feel that the faster [e-bike] speeds make riding more dangerous (i.e., decreases reaction time, easier to lose control and exceeding comfortable speeds), and others feel that it permits safer riding (i.e., keeping up with traffic and avoiding dangerous situations).” We note that riding on park administrative roads and trails generally does not involve “keeping up with traffic and avoiding dangerous situations” (e.g., such as merging into moving traffic), which suggests that the hazards of e-bike use on park administrative roads and trails may outweigh the perceived “keeping up with traffic” benefits of e-bike use in the context of a park.

The NPS narrative also states that “E-bike users, especially older users and those with physical limitations, use them to travel further distances, ascend hills with less effort, and reduce overall physical strain (MacArthur et al. 2014; Castro et al. 2019). Many e-bike users consider e-bikes to be an ‘equalizer’ allowing them to keep up with a spouse, friend or family member who is a faster cyclist.” (Emphasis added) While these statements are undoubtedly true for some older riders, NPS may be overgeneralizing the relative benefits to older riders by not providing statistical context regarding the proportion of e-bike users/owners who strongly value these perceived benefits. A 2022 study on the demographics of e-bike ownership by age in the United States provides such context. That study found that a relatively small percentage of e-bike owners could be considered “older.” The study found that, of U.S. e-bike owners, 46% were between the ages of 18-29; 38% were between the ages of 30-44; 14% were between 45-64; and 3% were 65 or older. In other words, 83% of e-bike owners in the U.S. are under the age of 45; and 17% are 45 or older, with only 3% being 65 or older.

Adding to our concern that the limited number of references cited by NPS may not provide the full picture of e-bike impacts, numerous other studies indicate that the severity of accidents on e-bikes is more serious than accidents on traditional bicycles, largely due to the differences in speed capability. For example, a study evaluated accident data collected through the United States Consumer Product Safety Commission’s National Electronic Injury Surveillance System (NEISS) between 2010 and 2017. The investigators found that e-bikes do, in fact, appear to be more dangerous than traditional bicycles. The study found that: e-bike riders are more likely to suffer from internal injuries; e-bike riding injuries are three times more likely to involve a crash with pedestrians; and e-bikes riders are more likely to suffer from concussions. The differences in severity of injuries were largely attributed to the difference in speed capability between e-bikes and traditional bicycles. We are providing additional references regarding the effects of the differences in speed capability in Appendix A at the end of this comment letter.

The analysis should include any monitoring data that NPS has or individual parks have collected regarding the numbers of e-bikes utilizing park administrative roads and trails compared to the numbers of traditional bicycles since the allowance of e-bike use under the Smith Directive. Evidence that e-bike users constitute a relatively small proportion of all bicycle users in areas closed to motor vehicles may support allowing e-bike use at those locations. A reasonable argument could be made that if e-bike use is relatively limited, the potential impacts of their higher speed capability would be manageable with effective mitigation measures, such as common sense “rules of the road” signage (e.g., “bicycles must yield to pedestrians” and “faster moving bicycles must yield to slower moving bicycles”) or speed limits on popular trails. In the absence of any monitoring data documenting a relatively low percentage of e-bike use on park administrative roads and trail, then NPS should err on the side of caution and acknowledge the fact that e-bikes not only have the capability of traveling faster than traditional bicycles, in many situations they do travel faster. And NPS should acknowledge that this difference in speed capability can and does contribute to user conflicts and safety concerns.

In sum, the potential for e-bike related user conflicts and safety concerns is well documented in the literature. And therefore such impacts are reasonably foreseeable and likely to occur unless e-bike use is properly managed and NPS limits such use to bike trail infrastructure that is designed for such use. We recommend that the PEA acknowledge the key differences between e-bikes and traditional bicycles and provide a meaningful analysis of those differences. We also recommend that that the PEA identify the change(s) in circumstances or conditions that would trigger parks conducting a fresh park-NEPA review regarding e-bike use; and specifically identify effective mitigation measures and best management practices (BMPs) for limiting impacts associated with e-bike use.

CLOSING COMMENT

The PEA is one of the few NPS NEPA reviews of e-bike use that has been opened for public comment. While we have concerns about some aspects of the PEA, as described above, we greatly appreciate the opportunity to comment on this important issue.

Sincerely,

 

 

Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013

 

cc:
Jay Calhoun, Chief, Division of Regulations, Jurisdiction, and Special Park Uses, NPS
Ray Sauvajot, Associate Director of Natural Resource, Stewardship, and Science, NPS

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Appendix A

Appendix A: Additional References Regarding the Differences Between E-bikes and Traditional Bicycles (Emphasis added to underlined sections below)

2009 St. Petersburg, FL study (UNC 2009)
Average speed of the bicycle riders was between 11 and 12 mph both before and after the bike lanes were installed.  https://pdfs.semanticscholar.org/bc0f/41ff8879aa6461a46a9a18c085562dba719b.pdf?_ga=2.235449477.50422134.1585934383-910238393.1585934383

2012 Preliminary British study on Bicycle Travel Speed: http://www.nilim.go.jp/english/annual/annual2012/39.pdf

The results showed that, while the e-bicycle was faster than the standard bicycle in terms of average free travel speed, their maximum speeds were the same (Figure 1).

2014 study in the Netherlands found that: “The results suggest that, after controlling for age, gender and amount of bicycle use, electric bicycle users are more likely to be involved in a crash that requires treatment at an emergency department due to a crash.” https://www.sciencedirect.com/science/article/abs/pii/S0001457514002668?via%3Dihub

2014 Dutch study: “Speed choice and mental workload of elderly cyclists on e-bikes in simple and complex traffic situations: a field experiment.” https://www.ncbi.nlm.nih.gov/pubmed/25463949

The study found: In simple traffic situations [such as on bike path, rather than in a bike lane]) the elderly cyclists rode an average 3.6 km/h faster on the e-bike than on the conventional bicycle. 

2015 Swedish study of average bike speed on mixed bicycle/pedestrian trails, including some use of eBikes: https://www.ncbi.nlm.nih.gov/pubmed/31560212

Results: The average speed of cyclists on the paths varied between 12.5 and 26.5 km/h (between 7.7 and 16.4 mph). As expected, the lower average speeds were found in uphill directions, near intersections, and on paths with high pedestrian flows. The higher speeds were found in downhill directions and on commuter routes. In all, 70%-95% of road users observed on pedestrian and cycle paths were cyclists, and 5%-30% were pedestrians. The most common type of bicycle was a comfort bike, followed by a trekking bike. Electric-assisted bicycles and racer bikes occurred at all sites, with proportions of 1%-10% and 1%-15%, respectively. The 2 sites with the highest proportion of electric-assisted bicycles and racer bicycles also had the highest average speeds. The differences in average speed throughout the day, week, and year could only be assessed at one of the sites. Only small differences were found, with the most noticeable being that the average speed was lower in January and February (13.8 km/h) compared to the rest of the year (15.3-16.1 km/h). The average speed was also lower during daytime (14.7 km/h) than during other parts of the day (15.4-15.8 km/h). 

Conclusions: The relationship between bicycle type and measured speed was not entirely clear, but the results suggest that paths with higher proportions of electric and racer bicycles have higher average speeds. There also appears to be a connection between average speed and the width of the distribution; that is, the higher the average speed, the wider the speed distribution.

2016 German study on “The influence of speed, cyclists’ age, pedaling frequency, and observer age on observers’ time to arrival judgments of approaching bicycles and e-bikes.” https://www.sciencedirect.com/science/article/abs/pii/S0001457516300914?via%3Dihub

The study found that “both the e-bikes’ potential to reach higher speeds and the fact that they reduce the perceived cycling effort increase the risk of TTA (i.e., time to arrival) misjudgments by other road users.”

2017 paper by University of Waterloo on “Usage Patterns of Electric Bicycles: An Analysis of the WeBike Project.”  https://www.hindawi.com/journals/jat/2017/3739505/

• Navigant Research estimates that the global e-bike market will reach USD 24.3 billion by 2025, with nearly 35 million unit sales estimated for 2016 [7].
• E-bikes are rapidly gaining acceptance as a desirable and viable alternative, and there is increasing municipal and consumer readiness to invest in cycling in general and in e-bikes specifically [12–14].
• Two e-bike field trials focused on safety issues. The first of these, Dozza et al. [24], used three fully instrumented bikes with front and rear cameras as well as brake pressure sensors. The data was used to identify potential safety issues related to sudden movement or braking. The main conclusion from this study was that e-bikes are faster than regular bikes and therefore new safety issues may arise when e-bikes interact with other vehicles on the road. Furthermore, the trips recorded in this study had an average duration of 14 minutes and an average speed of 17 km/h. The second safety-related study, Langford et al. [25], collected GPS data from a bikeshare at the University of Tennessee, Knoxville. The bikeshare had regular bikes and e-bikes. For both types of bikes, this study found similar safety issues, such as failures to come to a complete stop at red lights and stop signs and wrong-way cycling on one-way streets. Additionally, the average e-bike speed of 13.3 km/h was found to be higher than the average regular bike speed of 10.5 km/h.
• We also found one study, Schleinitz et al. [26], which focused on the speed of e-bikes compared to regular bikes. As in the field trials we mentioned earlier, this study found that e-bikes are ridden faster, especially by cyclists under 40 years of age. https://research.monash.edu/en/publications/e-bike-safety-insights-from-a-survey-of-australian-e-bike-riders
• In addition to field trials, there have been several surveys of e-bike owners in various parts of the world, including Australia (e.g., [27]), China (e.g., [10, 28]), Europe (see, e.g., [29]), and the United States (see, e.g., [21–23, 30]). The insights obtained from owner surveys are similar to those obtained from field trials: e-bikes are ridden faster than regular bikes and are often used for commuting and for longer trips.

2019 BYU study:  “Pedal-Assist Mountain Bikes: A Pilot Study Comparison of the Exercise Response, Perceptions, and Beliefs of Experienced Mountain Bikers”

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6711045/

Participants traveled approximately 5.5 miles (8.85 km) while riding the study loop. A paired t test analysis (Table 3) revealed participants completed the course an average of 12 min and 40 seconds faster when riding the eMTB as opposed to the conventional mountain bike (P<.001). The average speed of travel on the eMTB was 4.1 mph (6.6 km/h) faster than on the conventional mountain bike (P<.001).