Transcript Overview of Proposed EPA Engine Standards

Overview of Pending EPA
Marine Engine Standards
Richard Penna
February 14, 2007
Van Ness Feldman, P.C.
www.vnf.com
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)
• 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
Engine Type
Power
Outboard/
PWC
<40 kW
>40 kW
SD/I
<373 kW
>373 kW
HC + NOx
(g/kWhr)
28 – 0.3 x P
16
CO
(g/kWhr)
500 – 5.0 x P
300
5
5
75
350
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)
• 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
• 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
• 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/kWhr 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
• 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
• 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 phasein 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
• 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
• 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
Richard Penna
February 14, 2007
Van Ness Feldman, P.C.
www.vnf.com
Overview
• EPA’s anticipated marine evaporative standards
include requirements for:
– Low permeation fuel hoses;
– Fuel tanks;
– Canisters.
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
• 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)
• 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
– 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
• 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)
• 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
• Proposal expected to be signed late this month or in
March.
• EPA will likely provide stakeholders with a
minimum of 60 days for comments.