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PROPULSION REGULATIONS available for certain vessels with unique demands for speed The Maine Lobstermen’s Association supports EPA’s pro- and power. EPA writes that just one manufacturer has posed delay. Patrice McCarron is MLA’s Executive Director. certi? ed Tier 4 engines below 1400kW. But there are no McCarron writes that “the current Tier 4 marine diesel en-

Tier 4 engines, EPA asserts further, below 1400 kW with a gine emission standard is a mismatch for the Maine lobster power density greater than 35 kW/liter. ? eet.” MLA supports a phase-in through 2024 for certain vessels. If issues remain unsettled MLA wants permission to

THE DEVIL IN THE DETAILS keep operating Tier 3 engines after 2024.

Tier 4 phase-in started in 2014, and 2017 was the ham- Separately, many other workboat operators have Tier 4 mer-date for engines rated from 600 to 1400 kW. This concerns. Recall EPA’s “inspected” and “uninspected” de- phase-in was to give boat builders and manufacturers time lineation. That’s arbitrary, assert workboat operators, who for redesign and to certify compliance. For boat-builders, insist, ‘we’re facing the same challenges trying to ? t throaty

Tier 4 engine size and weight present challenges. power into small workspaces.’ Likewise, Tier 4 has been

On the one hand, EPA’s proposed delay is brief. An ini- an issue for American Waterways Operators (AWO) since tial phase would set model year 2022 as the implementa- 2017. A delay was highlighted in a letter to EPA in May tion deadline for most engines and installations. Model year 2017: “We are very concerned that, when an AWO mem- 2024 would be a second phase deadline for narrower set of ber company needs to secure a Tier 4 engine of the correct vessels that, EPA believes, “require additional lead time.” size and horsepower, there may be none on the market, or

However, delay and phase-in get more complicated be- the few that are may be very costly.” cause EPA also proposes a waiver system beyond 2024, if Regarding EPA’s current proposal, Jennifer Carpenter,

Tier 4 challenges continue. EPA also seeks comments on AWO’s executive VP and COO, reiterates these concerns. whether it would just make more sense to extend the later Carpenter supports EPA’s proposed delay. She writes that phase-in all the way out to 2028. towing vessel manufacturers have not been able to accom-

For example, lobster boats exemplify the Tier 4 engine- modate Tier 4 engines and that AWO is not aware of any vessel challenges. Prior to 2008, the boats stayed relatively towing vessel built since 2017, or under construction, with close to shore. Now, they travel 40 miles to more distant Tier 4 engines less than 1,400 kW (1,877 hp).

lobster beds. This requires more cargo space and more At EPA’s Bath hearing, workboat operators emphasized speed to complete a day’s work. Older, Tier 3 engines pro- the mixed issues of power, performance and safety. Erwin vide that power and speed. Thompson, for example, with Houma,LA-based LeBeouf

New Tier 4 engines are bigger and new pollution hard- Brothers Towing, conveyed support for EPA’s proposed ware demands even more space. Hence, the EPA logic says delay, asking that it include workboats “operating marine that the Tier 4 engines don’t ? t in existing hull models. diesel engines between 600-1,400 kW (805-1,877 hp).”

Plus, the additional heat generated by the

Tier 4 after treatment is no small thing, something that operators say will require additional space to protect the live lob- sters. Basic construction changes are needed but boat manufacturers, accord- ing to EPA, can’t progress with substan- tive redesign until Tier 4s are available and tested. Hence, the proposal to allow more time, to allow new engines to get in synch with vessel demands.

INDUSTRY WEIGHS IN

As is customary with EPA’s rulemaking, the Agency solicited public and industry comments. The deadline in this case was

October 21. In addition, EPA held a pub- lic hearing on September 20 in Bath, ME.

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