Boatbuilders must act quickly to mitigate the full impact of regulations that begin taking effect in July
The Environmental Protection Agency wants to prevent hydrocarbons from getting into the atmosphere, and new regulations are prompting a radical overhaul of fuel systems for gasoline- powered boats.
Though the regulations were approved in 2008, some boatbuilders are just beginning to consider how they will comply with the new rules, which in some cases are set to kick in this July. That's partly because the industry had to scramble to adapt automotive technology - some of which has existed in cars since the 1970s - to boats. It might also be because the long-winded recession has forced many companies to operate with bare-bones staff, and some have spent the bulk of their time and energy focusing on survival.
Despite the timing, members of the American Boat and Yacht Council and the National Marine Manufacturers Association are trying to get this point across: The deadline is drawing near, and builders that haven't addressed the emissions issue need to start.
"I think the longer you wait, the more flexibility in how to handle it you give up," says George Bellwoar, vice president of sales and marketing for Perko Inc., a marine hardware and accessories manufacturer partnering with car parts maker Delphi on the development of carbon canisters, one option for capturing hydrocarbons.
"One of the problems is the industry has, as a whole, downscaled dramatically," Bellwoar says. "Builders have trimmed their staffs as low as possible, so they don't have the staff they had two or three years ago, and now they're hit with something complex, and they don't have engineering staff to do it."
Builders need apply
Builders that haven't already requested extra time to get their entire fleets compliant with one portion of the new standards - the diurnal emission part - should do so now, Bellwoar says. Builders must request the appropriate allowance for their company size, submit the request and wait for the EPA's approval. Allowances differ for small and large builders (see box).
"Builders do have one advantage; they can use the extensions," Bellwoar says. "There's a small-business waiver or the 50 percent approach larger builders can take. If they plan right, they can delay the impact."
Larger builders with several boat models might get half their sales from three models, Bellwoar says. If builders address emissions on just those three, they can stretch out the impact. He says builders should ask themselves: Can I do as few as possible and still comply? Or, do I have a model with problems with the fuel system? Those are the models they should focus on first, Bellwoar advises.
The phase-in approach helps a builder delay the cost of the system on each boat, says Brian Scott, fuel systems manager with Attwood Corp., a Brunswick-owned accessories company that is working with Stant Corp., another leader in automotive fuel systems. Attwood has developed both a carbon canister solution and a pressure-relief system.
Any delay would allow the builder to focus on a few models at a time and perfect each before moving on to the next, Scott says. "That certainly gives them more time, but time is really passing very quickly, and at this point builders should have direction on how they will address this," he says.
There are two sources of hydrocarbon emissions, says John Adey, vice president and technical director at ABYC.
- Diurnal emissions: Diurnal emissions occur during the natural heating and cooling cycles of the day. When a boat heats up in the daytime, fuel expands and hydrocarbons come out of the vent line. When the air cools, the fuel contracts and pulls in fresh air, creating a vacuum. Builders have to either find a way to stop hydrocarbons from escaping as fuel expands or work with a third party that has come up with a preventive solution. There are at least two potential solutions: a carbon canister or a pressure-relief system.
- Evaporative emissions: Hydrocarbons can permeate plastic fuel tanks. New laws will require tank manufacturers to find ways of stopping permeation. Hoses were another source until last year, when manufacturers had to stop permeation from those as well.
The new rules apply only to gasoline fuel systems for two reasons, Adey says. Diesel fuel doesn't evaporate or permeate like gasoline, and far more boats are gas-powered than diesel-powered, so the impact is greater.
The EPA's objective is environmental safety, so the ABYC expanded on the requirements for maintaining personal safety, Adey says. Once the regulation to capture hydrocarbons was passed, the NMMA worked to convince the EPA to accept ABYC's additional standards requiring an automatic shutoff, Adey says.
Although automatic shutoff has been required in cars for years, boaters filling tanks always had to pay close attention to avoid overfilling, which would cause gas to land either at their feet or in the water. That prompted the ABYC to take a "radical" step, Adey says, and require that boats have the automatic shutoff - valving that works in conjunction with the fuel nozzle's shutoff - that cars have had for decades.
"The key is the carbon canister has to remain void of fuel," Adey says. "And if you've ever filled a boat, half the time it spits out the vent. If it spits out the vent, it's going to end up in the canister."
Automatic shutoff will ensure there is space in the tank so the vent doesn't get wet. The requirement, known as H-24, can be viewed on the ABYC website. (ABYC members have access to H-24 at www.ABYC.com; non-members can sign up for a five-day free trial to view H-24 in full.)
"It's a radical change from what we've been doing," Adey says. "The argument was, we're redesigning the fuel system - now's the time to do it. We should've done it 20 years ago, but we didn't."
That requirement will begin in 2012, Adey says (see timeline for all requirements). There are two paths builders can take: design-based certification or performance-based certification. Design-based certification aligns with already-accepted standards, such as the carbon canister or the pressure-relief system. Performance-based certification allows for new technologies to enter the marketplace, but it requires testing to be sure they are viable, Adey says.
All of the standards the EPA and ABYC put forth leave it completely open as to how builders address the issues. Some are looking to third-party companies such as Attwood and Perko for help, some are asking those companies to do it completely, and a few are doing it themselves, Adey says.
To mitigate diurnal emissions, systems either have to capture the hydrocarbons or do something else with them. Some vendors and builders are using carbon canisters to capture those hydrocarbons, Adey says. Attwood and Perko are two companies that have developed solutions using canister systems, and another is on the way, Adey says.
The canisters are in the vent, and there is a formula for tank size versus canister size, Adey says. The canister is known as a "passive purge canister," Adey says. In a car, a vacuum sucks the hydrocarbons out of the canister in what is known as an "active purge canister." That wasn't practical on boats, so in the passive purge the natural cooling of the fuel causes it to contract, pulling in fresh air. The carbon in fresh air breaks down the hydrocarbons, Adey says.
Compliance will force a redesign of fuel tanks or a reduction in usable capacity, says Bill Erdman, director of engineering at Nautic Global Group, which builds Rinker, Hurricane, Polar Kraft and Godfrey boats. "Some builders might not have enough room to increase the ullage volume" - the amount of unused space in the fuel tank - without reducing tank capacity or changing the deck, which would be very expensive, Erdman says.
In at least a few of the fuel tanks Nautic uses, the actual capacity is 6 or 7 gallons beyond the advertised capacity, so the stated tankage in brochures might simply have to be reduced by a gallon or so, he says.
"But that might not be true for all my tanks," he says.
Exemptions • PERCENT OF PRODUCTION ALLOWANCES: From July 31, 2011, through July 31, 2012, builders may produce up to 50 percent of their vessels that are exempt from the diurnal emission standards. Beginning Aug. 1, 2012, all installed marine fuel tanks and vessels must meet the diurnal emission standard. • SMALL-VOLUME ALLOWANCES: From July 31, 2011, until July 31, 2013, small-volume manufacturers may produce up to 1,200 vessels that are exempt from the diurnal emission standards. A small-volume vessel manufacturer is defined (in 40 CFR Part 1045.801) as having 500 or fewer employees, where the number of employees includes employees working for a parent company and all of its subsidiaries.
With a pressure-relief system, hydrocarbons in the fuel tank are maintained to a maximum pressure of 1 pound per square inch, Adey says. In present fuel systems, as fuel expands in the heat of the day, hydrocarbons are released through the vent to avoid pressure buildup. With a pressure-relief system, the vent won't open until pressure hits 1 psi (to avoid a potential explosion). However, that would occur under such extreme temperature changes that the EPA believes it would happen so rarely that the environmental impact would be negligible, says Adey.
Some builders want to explore the pressure-relief system first, says Scott, but canisters often are the cheaper and easier solution. "The pressure-relief system is going to inherently produce more of a pressure drop, and that may or may not be compatible with a particular vessel. All that means is the builder has to think about that and have a partner to help them think through those issues," he says.
"We just caution our customers - before they make a blanket decision going one way or the other - to figure out which way is appropriate for each vessel," Scott adds. Attwood has a solution using a pressure-relief system. Perko wanted to focus initially on its canister system and will later develop a pressure-relief system, Bellwoar says.
Mum's the word
Attwood and Perko have installed systems for clients, but declined to identify the companies they are working with. Tracker Marine is developing its own system, Adey says, but company officials aren't disclosing details.
"The engineering group is working on every fuel system component - tanks, hoses and fittings - to make sure they are in complete compliance with the new EPA standards," the company says in an e-mailed statement. "We are designing and developing new fuel systems that will keep our product in conformance with the new standards that are set forth."
Several other builders say they don't want to give competitors clues about how they were working toward compliance. Ski boat and bass boat builders have more challenges because of the long, narrow tanks in those vessels, Adey says.
Some builders are relying on tank manufacturers for a solution, Erdman says. Niles Schurle, mechanical engineer at Cobalt Boats, says he is working with Inca Molded Products, Cobalt's fuel tank manufacturer. "We're still in that process of trying to determine what the best package is going to be for our boats," he says.
As a member of the American Boatbuilders Association, a buying group of independent boatbuilders, Cobalt was awaiting an invitation-only meeting with vendors and suppliers to explore options and possibly make firm plans for a specific system.
"Two years ago, these parts were not available, so as a boatbuilder we had to start talking about it and putting pressure on vendors," Schurle says. "You can't just take an automotive system and convert it over to marine. It's more difficult than that, unfortunately."
Nautic Global Group has been working with Enviro-fill, which Ameri-Kart, a manufacturer of molded plastic fuel tanks, recently bought, Erdman says. If he gets all of the exemptions he requested for Nautic, which falls under the small-builder classification, he should initially only have to certify five or six of his tanks, he says.
Nautic is still determining which path to take but has been working closely with vendors for a year to address the new laws, Erdman says.
Cobalt is trying to anticipate potential drawbacks for boat owners and says it will try to find engineering solutions while designing the system.
"One of my concerns is about the end result to consumers," Schurle says. "Will there be problems with the tank filling slowly? Or differently? Everything we're doing is complicating the fuel process and we're also adding more parts and complicating the whole system."
But he thinks today's engineering challenges will pay off in the long term. "I believe there will be many benefits to this down the road," he says. "I just think the interim is a challenge for manufacturers, plus there are going to be possible customer concerns that we'll have to work through."
The longer builders take to address the new laws, the less flexibility they will have, Erdman says. That could mean revisiting certain models a few years later to make a better system, costing a builder time and money.
"If you're a builder and you don't have a sense about this, you've just got your head in the sand," Adey says. "You're going to have to ... call a third party."
Builders also will have to educate service technicians about the system they use, making it more favorable from production and servicing points of view to use consistent solutions.
Technology and cooperation
Attwood and Perko are just two companies working on the evaporative emissions problem, but they are the two that have been involved in marine components the longest, Adey says. Both have worked with many tank manufacturers to create a complete system for builders to address diurnal and evaporative emissions.
Only plastic tank manufacturers will be affected by the evaporative emissions problem because hydrocarbons do not permeate aluminum tanks.
Erdman says progress is being made. "As we ask more questions, the problem has become more simple," he says. "But there is still an engineering challenge, and there are still some costs associated with it."
Tank manufacturers have come up with a variety of methods to achieve low permeation, Erdman says. Some are using special coatings, Adey points out.
Ameri-Kart, which made the tank Nautic is working with, is making recommendations on fills, valves and hardware needed on the tank after Erdman gives the tank's static position.
With 24 years in on-highway industries, Erdman says he is familiar with emissions standards on trucks and motorcycles, so the undertaking feels less daunting to him than it might to those with little emissions experience, he says.
Erdman says one tank supplier told him the cost of tanks is expected to go up between 40 percent and 90 percent because of the layers of coatings needed to prevent evaporative emissions. Tank size will factor into that cost because the larger the tank, the more surface area the coatings will have to cover.
"Once the permeation strategy is established, [the rest] will be real straightforward," Erdman says, because tank companies will just apply a barrier.
Attwood and Perko say they have worked with all of the major tank manufacturers to ensure they can create a system that is flawless.
All companies working on this will have to be open to working with others, even competitors, if that means the best solution for a builder, Bellwoar says. He also thinks that builders, despite production and service drawbacks, will see the need to address the problem on a boat-by-boat basis.
"I suspect every tank builder in the country and every component manufacturer in the country will be working together when this is all over," Bellwoar says. "I'll work with Enviro-Fill or Attwood. Builders may have one boat that uses Enviro-Fill and another that uses Perko."
That boat-by-boat approach means builders and vendors can't pin down prices yet because each vessel's system will be specifically tailored to that particular boat. "We're selling more of a system here versus a component," Bellwoar says. "So just to get to the point of making a quotation one has to invest a lot of time and effort. It's completely different from quoting another product we sell.
"That's one of the challenges, and I suspect our competitor has it as well. We have invested a lot of time and money and resources into this," he says, and that's before the company ever makes a sale.
Erdman says the manufacturing cost for Nautic is projected at $200 to $400 a boat. Nautic still is deciding how or even whether the company will pass that cost to consumers.
"If we did pass it on, it may be an $800 increase at retail," Nautic spokesman Steve Tadd says. "It would get marked up by the dealer, but ... we know the price point we want to hit with our products, so we might not be able to pass it on."
"The high-volume boats tend to be the low price points, and I don't think there's any getting around certifying those boats right off the bat," Erdman says.
Each solution will be different, but it's realistic for a builder to budget between $150 and $250 per vessel at the manufacturer level, Scott says.
"To the customers we talk to, it's a very significant impact," he says.
This article originally appeared in the March 2011 issue.