Comment Log Display

While replacing an engine with new benefits engine manufacturers it
may impose crippling costs on many operators, particularly in the
marine sector. It appears that the concept of replacement was
developed before a source of aftermarket aftertreatment systems was
available. If the objective is to reduce emissions, regulatory
measures must focus on the level of emissions leaving the stack,
not on forcing users to purchase new engines. 

In the marine sector this has worked very well for sulfur emissions
reduction. Because the supply of low sulfur fuels is problematic,
and no other practical alternatives exist, both EPA and IMP permit
the use of aftermarket sulfur scrubbers. We should approach NOx
emissions with the same  goal, to reduce emissions not promote
engine replacement as the only solution. We now have the technology
to achieve emissions goals without imposing such high costs to
users. Current thinking is very much a case of throwing out the
baby with the bathwater.

A large part of the problem in the marine sector exists because the
market is so small that engine manufacturers simple ignore that
market. Our customers operate large motoryachts which use
generators that are at the lower power level at which EPA Tier 4 or
IMO Tier 3 standards apply in order to enter the North American NOx
Emissions Control Area. Because the size of the engines fitted to
most of these vessels is not worth an engine manufacturer's
attention it has become, for all practical purposes, impossible to
fit generators sized for the application. In cooperation with our
German partner, we manufacture aftertreatment systems sized and
developed for this niche market but because current regulations
prohibit certification by any route other than the engine
manufacturer, it may become impossible to build yachts in certain
sizes. Because larger generators currently available use such large
aftertreatment systems the volume required to fit those generators
in engine rooms creates a cascade of regulatory barriers based on
vessel tonnage (volume) and problems associated with oversized
generators. The unintended consequences of current regulations
create serious problems for the yachting industry which, in my own
state of Florida alone, brings in more than $11 billion annually
and employs more than 136,000 people in Broward County. 

Because current regulations were developed before any other
solution was available, users are being forced to destroy perfectly
useable engines and spend very large amounts (even with government
assistance) to replace those engines that simply do not exist on
the market today. We can retrofit aftertreatment systems that meet
all emissions standards and deliver the environmental benefits the
regulations were intended to provide.