EPA on New Engines- repowering

[Tender Spirit]

I am replacing our old (1987) Yanmar. We would like to replace it with a Beta engine, without the turbo charge. It is not EPA compliant. What does that mean? Will I be able to go cruising with this new engine internationally? We live in and cruise in remote areas (Alaska mostly) without mechanics that have the specialized equipment to service the electronics on the new Yanmars. How can we be compliant, yet live in places where we have to do our own repairs?

[rslifkin]

Generally when repowering an older boat you don't need to meet the latest EPA specs. The engine just needs to at least meet the specs relevant for when the boat was built.

[Avionics_Joe]

Food for thought.
Look at the fuel burn rate for the new Yanmar and the Beta. Multiply by the # years you expect to cruse and see how much $ you might save in fuel costs over the life of the motor.

[FPNC]

What specific model Yanmar engine are you replacing?

[PippaB]

This whole topic is fraught with pitfalls, but the reality is that no one is ever going to look, with the exception of CBP if you are going through the boat importation process.

The exemption currently in place allows you to replace your existing engine with a new one that meets at least the same emission certification level as the engine being replaced (does not depend on the age of the boat, depends on the engine you are replacing). You must also install a replacement that is the highest tier level that will fit (i.e. if your original engine is Tier I, but there are substantially similar Tier II or Tier III engines that will fit you have to choose the highest available tier). Beta's replacement engines say they do not meet Tier III, but presumably they meet Tier II - I would ask them to confirm.

The caveats:

1. The exemption expires when the vehicle/vessel (not the engine) turns 40. Presuming your boat is of similar vintage to the engine, best get it done before things turn 40.
2. The engine being replaced must be destroyed, it cannot be sold/used (otherwise we may end up with your old engine and your new non-conforming engine both in operation and polluting).
3. The engine replacement can't be more than 50% of the value the vessel had before the swap.

The EPA summary:

(2) Replacement Engines
We are revising certain aspects of our existing provisions with regard to replacement engines, as described below. These requirements apply to all marine diesel engines, propulsion or auxiliary, regardless of marine application. Section 1042.601(c) provisions apply instead of the provision of section 1068.240(b)(3) that applies for other nonroad engines.

(a) Replacement With a Freshly Manufactured Engine
Under the current marine diesel engine program, an engine manufacturer is generally prohibited from selling a marine engine that does not meet the standards that are in effect when that engine is produced. However, we recognize that there may be situations in which a vessel owner may require an engine certified to an earlier tier of standards. The two most likely situations are (1) when a vessel has been designed to use a particular engine such that it cannot physically accommodate a different engine due to size or weight constraints (e.g., a new engine model will not fit into the existing
engine compartment); or
(2) when the engine is matched to key vessel components such as the propeller, or when a vessel has a pair of engines that must be matched for the vessel to function properly. To address these extreme situations, we amended existing regulation 40 CFR 94.1103(b)(3) to allow a manufacturer to produce a new engine which meets an earlier tier of standards if the Administrator determined that no new engine certified to the emission limits in effect at that time is produced by any manufacturer with the appropriate physical or performance characteristics needed to repower the vessel. An engine manufactured pursuant to this provision is subject to certain conditions:
The replacement engine must meet standards at least as stringent as those
of the original engine; the engine manufacturer must take possession of the original engine or confirm it is destroyed; and the replacement engine must be clearly labeled to show that it does not comply with the standards and that sale or installation of the engine for any purpose other than as a replacement engine is a violation of federal law and subject to civil penalty.

[David Mathis]

In all my years of boating and several boardings, the engine has never been checked. Registrations get checked then safety equipment is inspected, the holding tank gets checked, the bilge is checked for oil, placards are checked (no oil discharge and the garbage rules), then a few routine questions before leaving. It's always been a nice cordial check with no problems. No questions about the engines or the generator have been raised. How would the enforcement people know if the engines were a few years newer than the boat? None seemed to care. If the engine room is clean and without violations or hazards, they check the boxes, smile, then leave.
Entering Canada is easier. We're asked where we're going, how long the stay will be, if we have unopened liquor or wine, how many cigarettes, do we have guns, any prohibited plants, fruit, or vegetables, then the form is completed and we are free to go after the passports are checked and returned. We've never been asked if the engine has been changed.

[Kd9truck]

I am a Yanmar 4jh5e owner, the same motor powers the 3 launch’s that service our marinas 300+ mooring field. The oldest has 4 rebuilds on it, they rebuild every 10k engine hours. These boats are running 18 hrs a day 3 months at a time.
My suggestion would be to rebuild and get spares (injectors, fuel pumps, thermostats, filters etc.) I took an owners class given by an east coast (USA) distributor (Mack-Boring), I had a side chat with the 35 year me mechanic constructor, he said with every year there are tighter and tighter EPA restrictions. he added that most of the EPA restrictions are of nominal gains for the typical fuel consumption and engine hours that sailboats see. He added that the additional parts are expensive and have short life spans and are making it increasingly harder for the DIY owner.
His advice was just keep rebuilding and that 10k hrs to rebuild was a good landmark but if your motor is running well you can take it further.

That made sense to me
Cheers

[PippaB]

Originally Posted by Kd9truck

... I had a side chat with the 35 year me mechanic constructor, he said with every year there are tighter and tighter EPA restrictions. he added that most of the EPA restrictions are of nominal gains for the typical fuel consumption and engine hours that sailboats see. ...

The EPA has not changed marine compression ignition (diesel) engine emissions regulations since 2008 - except for a single rule modification in 2020 to waive some of the requirements because engine producers were not producing engines in a specific category that would meet the requirements. The last phase-in date for recreational vessels from the 2008 rule was in 2014, it has been fully 10 years since there has been any 'change' in recreational (and even commercial) marine diesel engine emissions standards in the sizes used in the vast majority of our boats (a little bit of waffling language because at the superyacht size there have been some changes). Prior to the 2020 waiver modification the last change at any size was 2018, and that was still just the phase-in from regulations published in 2008.

In other words, the EPA gave up to 10 years of advance notice to people (don't you wish the IRS would do that?) and has not made any changes that affect recreational vessels since that time.

[Kd9truck]

Originally Posted by PippaB

The EPA has not changed marine compression ignition (diesel) engine emissions regulations since 2008 - except for a single rule modification in 2020 to waive some of the requirements because engine producers were not producing engines in a specific category that would meet the requirements. The last phase-in date for recreational vessels from the 2008 rule was in 2014, it has been fully 10 years since there has been any 'change' in recreational (and even commercial) marine diesel engine emissions standards in the sizes used in the vast majority of our boats (a little bit of waffling language because at the superyacht size there have been some changes). Prior to the 2020 waiver modification the last change at any size was 2018, and that was still just the phase-in from regulations published in 2008.

In other words, the EPA gave up to 10 years of advance notice to people (don't you wish the IRS would do that?) and has not made any changes that affect recreational vessels since that time.

Ok Pippa, then I remember the governing agent wrong, but emissions regulations have definitely tightened and continue to tighten and you can see it on the motors themselves. We saw a side by side comparison. Very well could be at the state level and the engine manufacturers build to the most stringent standards. Like how California has driven the automotive standards in the U.S.
my opinion stands with the rebuild over buying new and reconfiguring.
That’s just my opinion to the OP.
Cheers

[PippaB]

Originally Posted by Kd9truck

Ok Pippa, then I remember the governing agent wrong, but emissions regulations have definitely tightened and continue to tighten and you can see it on the motors themselves. We saw a side by side comparison. Very well could be at the state level and the engine manufacturers build to the most stringent standards. Like how California has driven the automotive standards in the U.S.
my opinion stands with the rebuild over buying new and reconfiguring.
That’s just my opinion to the OP.
Cheers

Emissions standards for on-road vehicles have changed much, but the Tier 4 emissions standards for non-road compression ignition engines were published in 2008. And those don't even apply to [most] recreational vessels.

2008 Category 1/2 Engine Rule—A regulation signed on March 14, 2008 introduced Tier 3 and Tier 4 emission standards for marine diesel engines [73 FR 88 25098-25352, 6 May 2008]. The Tier 4 emission standards are modeled after the 2007/2010 highway engine program and the Tier 4 nonroad rule, with an emphasis on the use of emission aftertreatment technology. To enable catalytic aftertreatment methods, the EPA established a sulfur cap in marine fuels (as part of the nonroad Tier 4 rule). Sulfur limit of 500 ppm becomes effective in June 2007, sulfur limit of 15 ppm in June 2012 (the sulfur limits are not applicable to residual fuels).

The Tier 4 standards apply only to recreational marine diesel engines with more than 2,000 hp, so larger sport-fishing vessels will still be required to have these large and expensive catalytic converters on board.

Tier 3 applies to the vast majority of boats on this forum, and the published limits have not changed since they were published in 2008. And implementation has not changed since 2014.

For the very smallest of diesels 40CFR89.1xx applies rather than the marine diesel standards, and those standards were implemented from model years 1996 through 2008.

[GordMay]

PippaB:
Thanks, for your several contributions, quoting EPA regulations.
Can you provide links, to on-line sources, for your citations?

[nofacey]

Circumnavigated, no one in any country ever asked about EPA rating of engine.

Have bought & sold a couple boats in last 5 years, surveyor, dealer, state don’t look at engine EPA either.

It’s an unenforceable reg that likely affects new boat manufacturers - and that’s about it.

For a used boat, go with the simplest, most reliable engine you can - it’s your life.

[sv Stella Maris]

FWIT, to echo above…

I have only seen issues arise with US authorities for ORIGINAL engines that did not meet the regs AND are applying for importation “VAT Paid” (some Hyundai marinzed diesels and others) (built outside the USA or Europe)

Once the vessel is documented, I have not seen nor heard of anyone checking further even when engines are replaced…’assumed-compliance’.

[jfischgrund]

You can replace one non-compliant engine with another. I recently replaced a Yanmar YSM8 (one cylinder) with a new Yanmar 1GM10, also one cylinder. You have to fill out an EPA form and send it in and hope it comes back promptly (mine did). You have to promise not to use the old engine again and you must save all the important parts for 18 months.

[Shaneesprit]

No way I will ever put a modern diesel in my boat.
Mechanical engine preferably without turbo, I would go Electric before I did that.