OFA provides comments to the Ministry of Transportation on the safety of the e-bike pilot program proposals. OFA recommends all operators in control of cargo E-bikes using the roadway, be required to have at minimum a G2 or M2 driver’s license, so they have a rudimentary knowledge of the proper rules for safe driving. We recommend the minimum age of the operator align with Ministry of Transportation driver’s license requirements. OFA recommends helmet use for all drivers and passengers of even the least motorized bicycle – a moped. To ensure clarity and awareness of enforcement, we recommend E-bike and Cargo E-bike regulations, requirements, and exemptions be applied as consistently as possible to the existing types of off-road vehicles that have on-road allowances. We recommend the regulation for Cargo E-bikes include a minimum age for passengers.