Published on November 7, 2007
Overview of Pending EPA Marine Engine Standards: Overview of Pending EPA Marine Engine Standards Richard Penna February 14, 2007 Overview: Overview EPA’s anticipated marine engine standards include: Emissions standards for sterndrive/inboard (SD/I) engines (including high-performance engines), outboard engines, and personal watercraft (PWC). Overview (continued): Overview (continued) While the draft preamble discusses many of the important implementation options and alternatives suggested by NMMA and its members, the proposed rule language does not. Detailed comments (supplemented with data) must be submitted by industry to ensure that the implementation options and alternatives EPA discusses in the preamble will be adopted in the final rule and well-supported by factual information. Expected Emissions Limits : Expected Emissions Limits Expected Implementation Schedule for SD/I: Expected Implementation Schedule for SD/I SD/I Emissions Standards EPA’s regulatory language proposes implementation of the emissions standards for all SD/I engines in 2009, one year after California’s standards take full effect. Small businesses have until 2011. EPA plans to request comment on several other alternative time frames for implementation: Require implementation in 2010 for engines not using catalysts in California in 2008, e.g., 4.3L or 8.1L, and implementation in 2009 for all others; A phase-in approach over the 2009-2010 period and an ABT program; or The industry-supported approach that would require implementation in 2010 for all SD/I engines, except for the 4.3L or 8.1L, and 2011 for the remainder. Expected Implementation Schedule for SD/I (continued): Expected Implementation Schedule for SD/I (continued) It will be critical for the marine industry to provide factual support for the proposed industry alternative outlined in the preamble. A phase-in option does not work with how this industry is structured. 2009 is not technologically feasible—too many configurations. High Performance Engines—HC + NOx: High Performance Engines—HC + NOx HC + NOx standards—EPA plans to ask for comment on two alternatives. Alternative 1: 5 g/kW-hr standard with emissions credits. “Small volume manufacturers” would get a standard in the range of 15-22 g/kW-hr. EPA will propose a definition for “small volume manufacturer.” FEL cap of 22 g/kW-hr for all manufacturers. Alternative 2: Standard set in the range of 15-22 g/kW-hr for all manufacturers and disallow use of credits. High Performance Engines—CO : High Performance Engines—CO EPA plans to propose a 350 g/kW-hr CO standard for high-performance engines. EPA believes that this limit is achievable with more control of air-fuel ratios under idle conditions. EPA will ask for comment on whether to use a CO standard of 25 g/kW-hr based on four mode duty cycle (excluding mode 1 – full power) instead and a CO cap (e.g., 350 g/kW-hr) for mode 1. Comment will also be requested on an average 25 g/kW-hr level with a 75 g/kW-hr FEL cap. This approach would address the new SD/I engines (4.1L and 6.0L supercharged) anticipated in 2009. High Performance Engines: High Performance Engines EPA plans to propose provisions to simplify exhaust emission certification and compliance as well as an exclusion from the not-to-exceed emission standards. According to the draft preamble, engines used solely for competition would not be subject to the proposed regulations. Industry will need to provide comments supporting the most flexible and feasible approach. Comments should provide specific input on the costs, advantages and disadvantages of the different approaches as well as the technology required by the various emissions levels. Expected Implementation Schedule for Outboard/PWC: Expected Implementation Schedule for Outboard/PWC Outboard and PWC Emissions Standards Expected regulatory language will propose implementation of the emissions limits in 2009 (same as California 2008 standards). For outboard engines, EPA will ask for comment on a modest phase-in of the standards to allow for the turnover of higher-emitting engines. Phase-in could give an extra year for a small percentage of the engines; or Phase-in could take the form of a certain percentage of the standard. Industry will need to submit detailed comments providing any supporting information/data that would bolster EPA providing additional transitional flexibility. Not-To-Exceed (NTE) Limits: Not-To-Exceed (NTE) Limits EPA is expected to propose NTE zones for determining compliance with the SD/I, outboard, and PWC emissions limits in the rule. EPA plans to request comments on four proposed NTE zones and asks for comments on alternative approaches. Industry has recommended alternative approaches for NTE limits to address variability of test modes. First approach is to base NTE limits on modal test results from the certification test rather than fixed values. A multiplier would be applied to account for testing and production variability. Second approach (the Klak approach) would use a weighted average for the NTE limit rather than have individual NTE limits for each subzone. The weighted average emission level would be required to be below the standards (or FEL) and a single multiplier would be applied to reflect variability within each subzone. Stakeholders will need to provide detail on the advantages of the alternative approaches and how they will improve in-use emissions and potentially the in-use testing program. Status of Package: Status of Package Proposal expected to be signed late this month or in March. EPA will likely provide stakeholders with a minimum of 60 days for comments. Overview of Pending EPA Marine Evaporative Standards: Overview of Pending EPA Marine Evaporative Standards Richard Penna February 14, 2007 Overview: Overview EPA’s anticipated marine evaporative standards include requirements for: Low permeation fuel hoses; Fuel tanks; Canisters. Overview (continued): Overview (continued) While the draft preamble discusses many of the important implementation options and alternatives suggested by NMMA and its members, the proposed rule language does not. Detailed comments (supplemented with data) must be submitted by industry to ensure that the implementation options and alternatives EPA discusses in the preamble will be adopted in the final rule and well-supported by factual information. Fuel Hoses: Fuel Hoses Low Permeation Fuel Hoses EPA is planning to require low permeation hoses in 2009 for fuel lines. EPA believes that PWC and SD/I will not have problems with this requirement given that most lines are straight-run pieces. Comments will be requested on an optional phase-in program for outboards. Implementation for fuel lines under the cowl would be delayed beyond 2009, provided that low permeation hose is used from the fuel tank to the engine beginning January 1, 2008. Permeation standards for primer bulbs would still go into effect in 2009. Phase-in could be 30% in 2010, 60% in 2011 and 90% in 2012, and possibly 100% in 2015. Fuel Hoses (continued): Fuel Hoses (continued) Industry will need to provide factual support for why 2008 and 2009 is not feasible for most hoses (including primer bulbs) and why more flexibility is necessary. Comments will also need to address how a phase-in could be implemented since the fuel line from the tank to the engine is installed by the boat builder while the under cowl hose is installed by the engine manufacturer. EPA is expected to suggest that installation instructions could specify low permeation fuel hoses and the engines would not be made available to boat builders who do not begin using low permeation hoses in 2008. Is this feasible?? Canisters: Canisters Canisters EPA is expected to propose that all vessels be equipped with carbon canisters. Small business concerns EPA will likely request comment on a three-year phase-in, e.g., 30%, 60%, 100% over 2010-2012 for small businesses, or One extra year of lead time to comply with diurnal standards. EPA plans to ask for input on which small businesses should be included—SBA definition (less than 500 employees) or annual boat sales? Comments will be needed to assure proper timing for testing and development of installation instructions for boat builders. Small Engine Mounted Tanks: Small Engine Mounted Tanks Outboard tanks less than 2 liters For outboard engines with small fuel tanks directly mounted on the engines, EPA will ask for comment on whether to exclude these from diurnal requirements. Proposal would impose permeation requirements on engine mounted tanks—could lead to material changes. Comments will be requested on whether sealed fuel tanks with pressure relief are a feasible alternative. EPA also plans to ask for comments on whether the proposed diurnal and running loss standards can be applied to these small tanks. Small Engine Mounted Tanks (continued): Small Engine Mounted Tanks (continued) The feasibility of complying with permeation requirements for engine mounted fuel tanks is a concern and comments must provide support for why these tanks should be excluded from diurnal and permeation requirements. Industry will need to comment on the feasibility of these requirements as well as provide viable alternatives. Status of Package: Status of Package Proposal expected to be signed late this month or in March. EPA will likely provide stakeholders with a minimum of 60 days for comments.