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Old 08-17-2015, 01:50 PM   #81
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Originally Posted by makobuilders View Post
I just received a lengthy reply from the legal counsel for the EPA, so let me get to the point:
  1. A homebuilt boat, built for pleasure use, is exempt from emissions requirements and can install any engine. However the boat cannot be sold for 5 years.
  2. A boat built by other than the owner (like a ship yard) is NOT exempt from emissions requirements, which as of now means Tier 3.
So the goal now is to find the most reliable Tier 3 engine, that has a "get home" emergency mode in case electronics fail. I am researching which, if any, Tier 3 engines are mechanically controlled.

Hope this helps some of you also.
That is matching what I am reading in the CFRs.

The EPA's statement 1 about home builds matches previous posts on this treat so that is good!

I thought the following EPA definition of a small boat builder interesting:

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Small-volume boat builder means a boat manufacturer with fewer than 500 employees and with annual worldwide production of fewer than 100 boats. For manufacturers owned by a parent company, these limits apply to the combined production and number of employees of the parent company and all its subsidiaries. Manufacturers that produce vessels with Category 3 engines are not small-volume boat builders.
There are many trawler boat builders that would fall under the small boat builder definition until you get to the last line. The last line is an Orwellian definition because the EPA/MARPOL require the use of Tier III regulations so therefore small-volume boat builders are not small-volume boat builders. And that backups up statement 2 in your post.

So far, the EPA has backed off requiring Tier IV engines in our size boats. This is a good thing because Tier IV is going to mean the use of DEF(Diesel Exhaust Fluid) for most/many engines. JD states that the engines I am looking at would require .1-.3 gallons of DEF for every gallon of fuel burned. If a boat had 1,000 gallons of diesel on board, you would need to have 30 gallons of DEF storage, maybe more depending on your comfort level of finding DEF in a remote location. The JD engines will run without DEF but at reduced HP.

Later,
Dan
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Old 08-17-2015, 02:04 PM   #82
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Mako

With all sorts of advice on how to skirt the law and get yourself and boat in heaps of trouble, there is a much simpler solution. Buy a fixer upper that has the hull design you desire, gut it and install a rebuilt Cummins or similar cost effective engine offering factory warranty.
...
If you have FRP skills check out the N46 that is mentioned on another thread.
...
Nope, that would be skirting the law, at least with that N46, and most old boats. EPA prohibits that type of activity as a way to escape the regulations.

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New vessel means any of the following:

(1) A vessel for which the ultimate purchaser has never received the equitable or legal title. The vessel is no longer new when the ultimate purchaser receives this title or it is placed into service, whichever comes first.

(2) For vessels with no Category 3 engines, a vessel that has been modified such that the value of the modifications exceeds 50 percent of the value of the modified vessel, excluding temporary modifications (as defined in this section). The value of the modification is the difference in the assessed value of the vessel before the modification and the assessed value of the vessel after the modification. The vessel is no longer new when it is placed into service. Use the following equation to determine if the fractional value of the modification exceeds 50 percent:

Percent of value = [(Value after modification)−(Value before modification)] 100% (Value after modification)

(3) For vessels with Category 3 engines, a vessel that has undergone a modification that substantially alters the dimensions or carrying capacity of the vessel, changes the type of vessel, or substantially prolongs the vessel's life.

(4) An imported vessel that has already been placed into service, where it has an engine not covered by a certificate of conformity issued under this part at the time of importation that was manufactured after the requirements of this part start to apply (see 1042.1).
Number (4) bites you if you build overseas, with a non Tier III vessel, and try to import into the US.

Later,
Dan
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Old 08-20-2015, 10:43 AM   #83
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ELECTRONIC vs. MECHANICAL CONTROL

FYI, I cannot find a single Tier 3 compliant engine that is mechanically controlled. Every single one that I have researched is electronic.

Gardner UK tells me that they are working on a solution (most likely involving catalytics on their exhaust) that may work for their engines, but that will take time.

So I have decided on a AGCO SISU 49CTIM for my installation. It has a "get home" ability in case the electronics fail.

For a marine tranny I'm leaning towards a Dong I commercial unit from South Korea. It also has the "get home" feature, which the ZF, Twin Disc and other marine gears don't have (not in my size anyway).
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Old 08-20-2015, 11:14 AM   #84
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I could not find a mechanically controlled Tier 3 engine either.

Replacement ECMs, injectors, etc for the JD 4045 engines were not that expensive. The electric engines do have advantages such as engine monitoring. However, what is a problem is that the JD 4045 Tier III engine gets worse fuel burn than the Tier II engine. I think at cruising speeds, the Tier III was burning about 15% more fuel. Even at today's low fuel prices that is an expensive 15%. Or to look at this from a different perspective, one would have a 15% greater range with a Tier II engine vs Tier III.

Later,
Dan
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Old 08-20-2015, 11:18 AM   #85
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But we have to adhere to Tier 3, so we just have to live with the fuel burn. BTW, the Deere 4045AFM85 did not have "get home" capability. So that and price are why I ruled it out.
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Old 08-20-2015, 11:22 AM   #86
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Originally Posted by makobuilders View Post
But we have to adhere to Tier 3, so we just have to live with the fuel burn.
Unfortunately that is the case so far.

Unless we home build.

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BTW, the Deere 4045AFM85 did not have "get home" capability. So that and price are why I ruled it out.
Get home is important but I figure if we have the spares to fix the likely failures we should be good. Plus we want a boat with a sail rig that would get us home as well.

Later,
Dan
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Old 08-20-2015, 01:22 PM   #87
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Plus we want a boat with a sail rig that would get us home as well.
Thanks for reminding me. I need to design an emergency sail system without resorting to a large, permanent mast, and it does not have to be big enough for roll reduction. One or two knots relatively downwind is better than sitting like a dead duck in the ocean.
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Old 08-20-2015, 01:51 PM   #88
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Unfortunately that is the case so far.

Unless we home build.

Later,
Dan
Just a few thoughts.

The same sort of regs apply to home built aircraft, and many people employed a separate company to 'home build' their plane for them.So the government inspection dept insisted on photo evidence that the registered owner was participating on the actual assembly.

So, as you've probably guessed, the owners took photos of themselves assembling bits: but they still employed ' qualified people' to build the a/c....

Maybe an option; employ some of the boatyard staff to build your boat ' privately' with your on site participation.
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Old 08-20-2015, 02:08 PM   #89
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My company has new-tech trucks.
Far too many sensors that can do fail, shutting down or reducing engine power.
Trouble-shooting is not simple or intuitive.
I wish I could replace them with a basic engine!

Ted
Most of the lumber guys around here buy the glider kits . We had one come in today, brand new Peterbilt day cab with a factory rebuild Detroit . Nice new truck without all the epa stuff.
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Old 08-20-2015, 02:47 PM   #90
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But we have to adhere to Tier 3, so we just have to live with the fuel burn. BTW, the Deere 4045AFM85 did not have "get home" capability. So that and price are why I ruled it out.
The Sisu is Bosch common rail. I have no idea what it's get home capablility comes from, but no common rail engine that I know of will run at all after a computer failure.

And yes, I don't think any of the higher tier engines are mechanical. Some have cam driven electronic unit injectors, and it is getting hard for those to comply. All the rest are common rail.

Consider getting a six cylinder. Smoother and better sound note.

You do like going in oddball directions. I never heard of Sisu and had to look it up!!
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Old 08-20-2015, 03:19 PM   #91
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Just a few thoughts.

The same sort of regs apply to home built aircraft, and many people employed a separate company to 'home build' their plane for them.So the government inspection dept insisted on photo evidence that the registered owner was participating on the actual assembly.
...
Maybe an option; employ some of the boatyard staff to build your boat ' privately' with your on site participation.
I suspect one could do this an be legal up to a point. I do not see anything in the EPA regulations that would prohibit this at all. The closest regulation might be around 50% build requirement. One could certainly get the hull built by a yard and then do the interior. The hull on a metal boat is a small part of the work effort and cost so I don't think the EPA would care. Certainly one could contract out other work on the boat.

The problem with a home built is that one is looking at a good 5-10 years to do a build.

Later,
Dan
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Old 08-20-2015, 04:14 PM   #92
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I suspect one could do this an be legal up to a point. I do not see anything in the EPA regulations that would prohibit this at all. The closest regulation might be around 50% build requirement. One could certainly get the hull built by a yard and then do the interior. The hull on a metal boat is a small part of the work effort and cost so I don't think the EPA would care. Certainly one could contract out other work on the boat.

The problem with a home built is that one is looking at a good 5-10 years to do a build.

Later,
Dan
I built a 60' steel barge in 2 summers with some help on the underwater section welding.

My idea would be for you to just get the hull/engine installation done under the homebuilt regs, get approval and launch .....then give the fit out to a professional yard.

The inspectors would expect a home built to be launched as a bare hull/ engine, with the interior fitted out as money became available.

So if you comply with the inspection phase and get approval, then you can let loose with the pro's ......

Most steel hulls are about 1k per foot fabricated, so you can estimate the hours by dividing by the trade hourly rate plus 50% for margin approx. You ( part time) and two pro's ( full time)could build a big hull in 6 months....
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Old 08-20-2015, 04:45 PM   #93
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Here's some prices for hull/deck from Holland, click on PDF price list button to download.

https://www.bonitoboats.eu/products/hull___deck.html
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Old 08-20-2015, 06:40 PM   #94
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Doesn't Mitsubisshi have mechanical, tier 3 compliant engines? I don't know if they have anything in your desired size, worth checking.
FPT (Iveco) had some on the shelf mechanical engines in stock that are tier 2 and can be used in new builds because they are in stock and were manufactured prior to tier 3 regs.
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Old 08-20-2015, 07:46 PM   #95
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Here's some prices for hull/deck from Holland, click on PDF price list button to download.

https://www.bonitoboats.eu/products/hull___deck.html
Thank you.

I added that link to my boating spreadsheet.

When we first started planning getting a boat, we thought about a home build but I quickly decided against that for a variety of reasons. I still think we won't build, BUT, due to our situation, a home build might actually work. The idea has always appealed to me and my dad bought plans to build a sail boat in the back yard so this is all his fault! He still has the plans but he bought a used boat instead of building. We have a variety of plans on how to do what we wish to do, so who knows which one will work out.

Later,
Dan
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Old 08-20-2015, 11:34 PM   #96
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Taken to the extreme, it's not very difficult to just document (on paper) with the USGC a homebuilt boat then go out and have a shipyard build you one and just stick your own Builders' Tag on it. Easy as pie.

However what does this do to resale?

Remember the old saying about being penny wise and pound foolish.
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Old 08-21-2015, 01:13 AM   #97
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Most of the lumber guys around here buy the glider kits . We had one come in today, brand new Peterbilt day cab with a factory rebuild Detroit . Nice new truck without all the epa stuff.

Glider up here had the rules changed. Now come without 2 majors of 3.
ie: rear-end and transmission but include the engine.
However weren't available for a 5-ton truck.

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Old 08-21-2015, 06:03 AM   #98
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Some one posted a listing of a 1973 27' Saga that had undergone a 3 year retrofit. It was on Yachtworld and they put a new 43Hp Beta (Kubota) engine in it and had a picture of the emission control label on it. It was Tier 4.
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Old 08-21-2015, 08:24 AM   #99
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I I think at cruising speeds, the Tier III was burning about 15% more fuel. Even at today's low fuel prices that is an expensive 15%. Or to look at this from a different perspective, one would have a 15% greater range with a Tier II engine vs Tier III.
Dan
So if tier III is 15% cleaner the II, but burns 15% more fuel for given HP, are we really getting anywhere? Or is this a typical government joke on us all, like ethanol.
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Old 08-21-2015, 10:22 AM   #100
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So if tier III is 15% cleaner the II, but burns 15% more fuel for given HP, are we really getting anywhere? Or is this a typical government joke on us all, like ethanol.
I have no idea on the emissions but I have asked myself the same question. One worry I have is will there still be Tier III engines after Tier IV has been in place for a few years? Are the differences between Tier III and IV minimal so that the engine companies can still provide both engine types? Seems like the marine market is pretty small and will the engine companies be able to provide both tiers?

Flip side is that how much pollution is really caused by these engines in the first place? The same organization that came up with these regulations also had sick people sitting in a booth breathing direct diesel emission from a 7.3 diesel. They said the tests were safe but if so, why do we need these new engines? If the emissions are NOT safe, then how come the researchers and EPA regulators are not in prison?

Later,
Dan
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