Reman Engine in New Build -- Tier III/IV Regulations

brianj

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I am not very familiar with the in's and out's of the new Tier II/III/IV regulations but my basic understanding is that newly built boats have to comply with these standards. I was curious to know if this only applies to federally documented vessels? This Holland 32 on YachtWorld is a 2011 hull with a remanufactured Cummins 8.3 and looks to be state registered. I don't believe the engine is Tier II emmissions certified, so what is the loophole for installing a reman engine in a new boat? I would suspect there is significant cost savings and am thinking if I did a build I would do a very basic boat at first with a reman engine, if possible.

Interested to hear what people know about the emission regs as related to state vs. federally documented vessels.

Thanks,
Brian

4474484_20130927131743431_1_XLARGE.jpg

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lobstercatcher

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The loop hole? There is none. I would assume the 2010 engine qualifies to be in a 2011 hull. If it were a 1995 remained there could be some issue if the whoever actually checked. Has anyone ever had that checked by some official capacity?
 
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BillD

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25 Terry Jason with Cummins 370 power
The loop hole? There is none. I would assume the 2010 engine qualifies to be in a 2011 hull. If it were a 1995 remained there could be some issue if the whoever actually checked. Has anyone ever had that checked by some official capacity?

As lobster stated there is no loophole with EPA regs. The engine pictured is a mechanical Cummins 8.3 6CTA. The engine is not Tier II compliant.

If the hull is an older hull and "repowered/rehabbed" in 2010/2011 and the sales pitch is that it's a "2011" because of the new motor then the boat could be in compliance.

If the hull is titled and registered as a 2011 then the non EPA compliant Cummins 6CTA installed is in violation of federal law. EPA Tier II regs would have been the minimum requirement for 2011 for commercial or recreational.

The USCG is entrusted with enforcement of the EPA rules. One would "think" that the USCG will enforce the rules that we paid billions of tax $$ for.

If I was interested in buying this boat I'd call the USCG and ask for a "waiver" BEFORE I decided to buy it. :rolleyes: Let's see how that would fly !!!!!:D

FYI—Federal regulation does not require new engines to be installed in new boats, only that they meet the EPA regs at that time. Cummins does have a company policy that says NO RECONS in new boats.. Not the law, just an internal policy.. One can meet EPA regs using a QSB recon or a used QSB/QSC.QSL, later QSM as they are all EPA Tier 2, if the boat is registered 2012 or earlier.

FWIW,

Bill D
 

brianj

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I contacted the EPA in regards to kit boats and there exists a Personal-use exemption to the Tier III regulations. Of course the exemption is open to some interpretation but I believe as long as one personally does the assembly (manufacture) of the boat to a completed state they do not have to install a Tier III compliant marine diesel.

Here is the EPA's response:

The regulations at 40 CFR 1042.630 (see the link at eCFR — Code of Federal Regulations and copied below) describe the personal-use exemption provisions. If your vessel meets the requirements listed there the engine installed is not required to be certified. If all the requirements are not met then a certified marine engine must be used.

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§1042.630 Personal-use exemption.

This section applies to individuals who manufacture vessels for personal use with used Category 1 engines. If you and your vessel meet all the conditions of this section, the vessel and its engine are considered to be exempt from the standards and requirements of this part that apply to new engines and new vessels. The prohibitions in §1068.101(a)(1) do not apply to engines exempted under this section. For example, you may install an engine that was not certified as a marine engine.
(a) The vessel may not be manufactured from a previously certified vessel, nor may it be manufactured from a partially complete vessel that is equivalent to a certified vessel. The vessel must be manufactured primarily from unassembled components, but may incorporate some preassembled components. For example, fully preassembled steering assemblies may be used. You may also power the vessel with an engine that was previously used in a highway or land-based nonroad application.
(b) The vessel may not be sold within five years after the date of final assembly.
(c) No individual may manufacture more than one vessel in any ten-year period under this exemption.
(d) You may not use the vessel in any revenue-generating service or for any other commercial purpose, except that you may use a vessel exempt under this section for commercial fishing that you personally do.
(e) This exemption may not be used to circumvent the requirements of this part or the requirements of the Clean Air Act. For example, this exemption would not cover a case in which a person sells an almost completely assembled vessel to another person, who would then complete the assembly. This would be considered equivalent to the sale of the complete new vessel. This section also does not allow engine manufacturers to produce new engines that are exempt from emission standards and it does not provide an exemption from the prohibition against tampering with certified engines.
(f) The vessel must be a vessel that is not classed or subject to Coast Guard inspections or surveys.
 

jwalka51

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I am pretty sure that ir is all good. From what I am told, if an engine has a displacement of 1.2 liters per hole or more, they were exempt from that bullshit
 

tunaorlater

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If I'm correct under 13 liter is tier 2 until January?
 
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