for children's bicycles, the regulations were soon expanded to include all bicycles except for track bikes and custom-assembled bicycles. That October, Forester published an article in Bike World denouncing both the California Department of Transportation and the CPSC. He targeted the new CPSC regulations, especially the "eight reflector" system, which required front, rear, wheel and pedal reflectors. The front reflector replaced the bicycle headlight. Forester argued that motor vehicle drivers about to cross the path of the cyclist would not see the cyclist because the headlights of their motor vehicle did not shine onto the front reflector of the bicycle, often resulting in a crash. (Only if the bicycle was directly in front of the car and only if the bicycle was headed the wrong way, would the car's headlights illuminate the bicycle's front reflector, until the inevitable head-on crash.) After the rules were finalized, Forester sued the CPSC. Acting as his own lawyer (pro se), Forester did not understand that United States federal law did not grant jurisdiction to the appeals court to review the technical merit of the rules (a so-called "de novo" review) unless the procedure used to create the rules was flawed. The CPSC argued that a challenger must prove the process was "arbitrary and capricious." The judge ordered a de novo review of the rules; threw out four of them, but left the "eight reflector" standard untouched. Forester, emboldened by this partial success, proceeded to launch further challenges to administrative rules in court, but did not duplicate that early success. His legal advocacy remains highly controversial. Famously abrasive and inflexible, Forester was critical of Dutch cycleways, stating them to be dangerous despite never having cycled in the Netherlands. In addition to legal advocacy, Forester was known for his theories regarding cycling safety. His Effective Cycling educational program, developed after his research which claimed that integrating motorists and educated cyclists reduced accidents more than creating separate bicycle lanes, was implemented by the League of American Bicyclists (formerly, the League of American Wheelmen) until Forester withdrew his permission for that organization to use the name. Death Forester died of complications related to a lingering flu on April 19, 2020, at the age of 90. Bibliography Statistical Selection of Business Strategies Chicago, Richard D. Irwin, 1968 Lib Cong 67-17054 Bicycle Transportation (First edition, 1977; Second edition 1994, The MIT Press, ) Effective Cycling (First edition, 1976; Sixth edition,