Attention California harbor craft operators: The days are
numbered for your dirty old marine diesels. Unless you already
have new EPA-certified Tier 2 engines (or Tier 3 when
available), you're going to have to get them sometime during
the next decade or so, depending on the age of your current
diesels and how much you use them.
Attention other U.S. commercial marine operators: Just
because you don't operate in the Golden State, that doesn't
mean you're off the hook. The U.S. Environmental Protection
Agency may not be as aggressive as California, but for the
first time the agency is actively considering mandates for
upgrading existing engines as well as stricter emissions
standards for new engines.
As most of the commercial marine operators in California
should know by now, the California Air Resources Board is in
the final stages of refining a proposal that calls for the
phased-in replacement of virtually all engines now powering
what the state calls harbor craft. This includes tugs,
towboats, ferries, and excursion and dinner boats.
The goal, according to Todd Sterling, CARB's team leader for
the harbor craft project, is to have Tier 2 or Tier 3 engines
installed on the boats by around 2022.
According to the draft CARB timeline released this spring,
affected harbor craft with engines manufactured prior to 1975
and that operate more than 1,500 hours per year will have to
install Tier 2-certified engines by the end of 2009. Newer
engines will have later compliance dates. (See table, opposite
page.)
Sterling told WorkBoat that his agency recognizes that
meeting these compliance schedules will be affected in part by
the availability of engines and the facilities to install them.
"We're trying to spread these replacements evenly over a longer
stretch of time," he said. "We don't want to overburden a
vessel owner with multiple vessels, and we don't want to
overburden the drydock and vessel repair facilities.
"We've also recognized the delays in getting engines, and as
long as the owner puts in an order to acquire an engine six
months prior to the timeline requirements, you're in compliance
with the regulation. Even though it takes another 18 months
beyond that [to get the engine installed], you're still in
compliance because you've recognized the need and put in an
order."
Vessel owners in California can also extend compliance
deadlines by implementing an emission control strategy on
existing engines that reduces particulate matter (PM) or oxides
of nitrogen (NOx) by at least 25 percent or by upgrading
non-certified - so-called Tier 0 engines - to Tier 1 standards
if completed before 2008.
Reducing the PM or NOx by 25 percent or more can extend the
timetable by up to five years. Rebuilding a non-certified
engine to Tier 1 standards establishes the rebuild year as the
new manufacturing date with a new compliance date to match.
But sooner or later, all California harbor craft will be
required to have bona fide Tier 2 engines. And if a compliance
date falls into the implementation timeframe of EPA's Tier 3
standards, they will have to install Tier 3s instead.
The effect of these new regulations on California operators
will be huge.
"This is really dramatic," said Susan Hayman, Foss Maritime
's vice president of health, safety, environment and quality.
"There won't be any cheap options. This will be quite a capital
intensive thing. Some alternative compliance measures like
fleet averaging could help, but something like this could be a
problem for some people."
John Walls, marine division director at Cummins Northwest ,
said he expects leveraged companies will have difficulty
complying and staying competitive. "Bigger companies with
larger capital bases will meet the standards but their rates
will go up," he said.
Hayman said Foss has over 20 vessels operating in
California, not all of which will be affected by CARB's new
regulations. But for those that are, many have older engines.
She said Foss must now figure out how best to proceed. Repower
or upgrade non-certified engines to Tier 1 to buy time?
"If you're sitting on a Tier 0, my understanding is that
your only option is to repower," she said. "Everything else is
just extending the timeline one way or another. It's either one
to five years by doing a NOx or PM reduction or by rebuilding,
but you're still in the cycle somewhere on that time compliance
schedule."
However, extending the timeline by reducing NOx or PM is a
lot easier said than done. "We have to get something that can
do that, right?" Hayman asked. "Someone still has to develop
that. There's not really anything out there that you can just
slap on to accomplish that. So there are lots of things that
need to be worked on for us to be able to comply, things that
are out of our power. We can work with the engine companies,
but we're dependent on them."
NEW EPA STANDARDS
Meanwhile, engine companies are looking down the barrel of
proposed Tier 3 and Tier 4 standards being developed by the
EPA. As the schedule now stands, Tier 3 standards, depending on
engine size, would be implemented between 2009 and 2014. Tier 4
will kick in between 2014 and 2017.
Jennifer Carpenter, American Waterways Operators senior vice
president for government affairs, said she expects the dates to
stand. She also said that engine manufacturers and the EPA both
claim that Tier 3 standards should be achievable without
exhaust aftertreatment.
Tier 4, however, will almost certainly require
aftertreatment and that will have a significant effect on
vessel design. "The technology of choice for reducing NOx is
selective catalytic reduction," Carpenter said. "This requires
a big tank for urea [to be injected into the exhaust stream],
which is heavy and takes a lot of room. So we're not just
talking about buying a new engine that just happens to be
cleaner, we're talking about changes in engine room design,
vessel weight and other significant alterations."
In addition to the potential design effects stemming from
Tier 4 standards, Carpenter said the industry needs to
understand the implications of the remanufacture provisions in
the proposed rules. "Up until this point, EPA standards for
marine engine emissions have applied to new engines. There
hasn't been anything that applies to existing engines when
they're overhauled. And while they've kicked around this
possibility in the past, I would say for the first time they
have signaled their intent to regulate remanufactured marine
engines.
"Rebuilt engines would have to be brought up to a standard,"
continued Carpenter, "and what that standard is, is not clear.
But the significant thing for everyone to recognize is that
probably for the first time, rebuild is on the table in a very
serious way."
"This [the remanufacture provision] is a big deal," said
Walls of Cummins. "It will be very expensive. And there will be
no grandfather clause. Once you've got it in there and operate
the product, you'll have to upgrade it every rebuild cycle. And
some of these engines on boats will have four rebuild
cycles."
For many commercial marine operators, all these proposed new
regulations probably seem especially stringent. But Hayman,
Carpenter and others see it as following a logical path.
"I think the EPA has been feeling increasing pressure to do
this," said Carpenter, "as a result of the aggressive program
in the state of California, as a result of the long lives of
marine engines, and as a result of the fact that they're
continuing to drive down emissions in other sectors. They're
seeing commercial marine as a bigger piece of the pie not
because it's getting worse, but because others are getting
better."
"This shouldn't be a surprise," said Hayman. "You don't stop
at Tier 1. You don't stop at Tier 2. I'm not surprised that
we're looking at Tier 3 or Tier 4. I'm surprised that other
people are surprised. There's going to be a Tier 5 and a Tier
6. It helps to have standards. I don't think that's a bad
thing."