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Prepare now to comply with EIAPP engine air pollution certificate

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By Dorie Cox

The EIAPP is a long acronym for a fairly simple document that confirms an engine meets current air pollution standards. The Engine International Air Pollution Prevention certificate is required for many diesel engines under Annex VI of MARPOL (International Convention for the Prevention of Pollution from Ships).

Although it can affect many yachts, there is some confusion about which ones need the certification and how to get it, said Andy Miles, a yacht broker with Westport in Fort Lauderdale. As member of the board of directors of the International Yacht Brokers Association (IYBA) Miles works with many maritime attorneys who deal with the transactional importance on a daily basis.

Captains, brokers and owners often learn of the engine document during the sale of a yacht, said Brian Fowler, marine engine consultant for Pantropic Power in Miami. And based on the number of calls coming into Pantropic, he said many in yachting realize they need the certification a bit too late.

“I just got a call yesterday from a broker who acted like he never heard of it. He said, ‘I can’t believe this is going to hold up the sale’,” Fowler said. “We need to get the word out, this needs to be common knowledge.”

According to the U. S. Environmental Protection Agency (EPA), the certificate is the internationally accepted documentation that a specific engine meets the international NOx emission limits for diesel engines.

NOx are oxides of nitrogen that form when diesel fuel is burned with excess air, according to Capt. Jeff Werner, a diesel engine expert with Diesel Doctor and Triton columnist.

There is misinformation about how important this document is, Miles said.

”Hardly any captains are aware of their exposure, and many captains have no idea what it is,” Miles said. “They’ve been running without them.”

Although the law was passed in 2008, implementation did not begin until 2009 and authority of enforcement did not begin until January 2015, he said.

Even though the document is typically part of the engine’s technical file to be kept onboard, Miles said obtaining it can take up to several months and include fees that have ranged from several hundred dollars to nearly $10,000.

Fowler cautioned that the request process may take time and it helps to plan ahead.

“It can be cumbersome and time consuming,” Fowler said, noting that he requests the document at the beginning of an engine order and recommends that others confirm it will be included in the engine documentation.

“I order it with every engine I build, whether they ask for it or not,” he said. When the document is ordered at the time the engine is shipped, it runs about $400, he said.

Because of the delay in receiving the certification, Miles said brokers have been able to show proof of good faith in the form of paid invoices that the certificates have been ordered along with a letter from a maritime attorney.

Another potential liability to the yacht owner for non-compliance is, according to USCG and EPA documents, that they may be subject to $25,000 fine per day, per occurrence. The U.S. Coast Guard, Homeland Security and other enforcement agencies also have the authority to ask for proof that the captain is in possession of these documents and that they are onboard at the time of inspection. No one interviewed for this story could confirm that any yachts had been fined.

The certification is not required on gasoline, propane, natural gas or other spark engines, and the following list can help a yacht captain or broker clarify if the yacht is required to have an EIAPP certificate.

As with many regulations, the answer can take a bit of research as to details on the engine’s age, size and possible alterations to the equipment.

The following diesel engines are required to be certified to the Annex VI NOx limits, as evidenced by an EIAPP certificate:
• Any engine above 130 kW that is installed on a vessel constructed on or after Jan. 1,
2000
• An engine above 130 kW installed on any vessel if the engine has undergone a major conversion on or after Jan. 1, 2000. This means:
• The engine has been replaced with a new engine built on or after Jan. 1, 2000; this requirement is extended to include replacement with any existing (used) engine, beginning July 1, 2010
• The maximum continuous rating of the engine has been increased by more than 10 percent
• The engine has been significantly modified, which means it has been modified in such a way that would increase its NOX emissions (for example, the fuel injector nozzles have been changed, a turbocharger has been added, or the timing has been changed).
The following diesel engines are not required to have an EIAPP certificate:
• Engines used solely for emergency purposes in life boats or for any equipment intended to be used solely in case of emergency
• Engines installed on drilling rigs and platforms and that are solely dedicated to the exploration, exploitation and associated offshore processing of sea-bed mineral resources.

If the EIAPP certification is not in the yacht’s paperwork, a place to start the process is at the beginning. Contact the builder or engine manufacturer for an application to supply basic information including the yacht’s hull identification number and/or engine’s serial number.

Sometimes finding that serial number, however, can require a bit of detective work, according to Todd Barnes, general manager at RPM Diesel in Fort Lauderdale.

“You have to know your engine to find it,” Barnes said. “Some are on the blower, the valve cover, or the heat exchanger. If the block has been subject to repairs, the original number may not have been transferred.”

The number can usually be found on decals, stickers or plates in a variety of locations on an engine, he said. But events such as a fire can damage the numbers, overzealous cleaning can scratch them off, or paint can cover them, Barnes said.

Another misconception is that a new engine has a sticker that states “this engine meets standard … .”
“Captains think that is their EIAPP; it is not,” Miles said. “Now they have added another decal that says this is not the EIAPP.”
Pantropic’s Fowler said the company receives many calls for the certification and callers are referred to the yacht engine manufacturer in the location of the build for the best way to get the certification.

“Many businesses are getting calls,” he said. “We try to divvy up the load. If it’s a Viking built in New Jersey, go to those guys, they know the hull, they are obligated to assist the boat builder all the way through.”

Newer engines are already built to the specifications and are compliant; it is just that many yachts do not have the EIAPP certification in their files. If people know about it then they can plan ahead and have it before selling a yacht, Fowler said.

“Don’t panic,” he said. “Find out a way to get ahead of it and start now to be ready for the boat show.”

 

Dorie Cox is editor of The Triton. Comment at dorie@the-triton.com.

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Dorie Cox is editor of The Triton.

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