8.
“Repower” means replacing an existing used engine with
another brand new or
reconditioned engine that meets meeting
current required emission standards
in effect at the time of
replacement repower., Repower including but not
limited to
major engine repairs on a damaged engine requiring a different
new
engine block.
Comment - Is the intension that this definition would require the
operator to repower the vessel to the most current engine emission
Tier should their existing engine suffer a failure that required
replacement of the engine block? Repowering to Tier 4 is orders of
magnitude more expensive than an engine rebuild including a block.
As an example, replacement of the block on a 32L Tier 2 engine was
approximately $50,000 in extra material expense. Recently,
repowering that vessel with Tier 4 engines was approximately
$750,000 per engine including 2-3 months in the shipyard. How can
operators stay in business not knowing if their maintenance costs
could include an extremely costly repower that would require
extensive engineering, shipyard time and modifications to complete?
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