i misinterpreted the rule and thought it was throttle up to 28mph. It seems "Councilmember Crystal Hudson has introduced legislation that would prohibit shops from selling or renting Class 3 e-bikes." would be entirely pointless then, since you can convert them trivially.

Can you build a "class 2" that is only governed to 20mph to get around this? I think these class 3s are the only way the USA will actually adopt the moped.