July 25, 2006

Mr. Phillip Carlson (ASD)

U.S. Environmental Protection Agency

Office of Transportation and Air Quality

2000 Traverwood Drive

Ann Arbor, Michigan 48105-2498

Dear Mr. Carlson,

I am writing to provide comments about the evaporative emission controls
being proposed for the marine fuel systems.  I attended the SBREFA
meeting held in Ann Arbor, MI on July 11, 2006 and these comments are a
repeat of my verbal comments at that meeting.  I am employed by
Grady-White Boats in Greenville, NC. We employ about 450 people. 
Grady-White builds coastal saltwater fishing vessels for recreational
use sized from 18’ to 36’.  Our boats are 100% outboard powered. 
Our fuel tanks are all permanently installed.

The majority of boat builders in the US are small business entities. 
North Carolina has over 100 boat builders and I believe only about four
of these employ more than 500 people, therefore, most are small
businesses like Grady-White Boats.  I believe this general business size
will be fairly normal across the U.S.

Certified Components and Reference Standards

Allow flexibility by the use of certified components and reference
standards to meet the regulations.  The USEPA will have a tremendous job
just communicating these new regulations due to the large number of very
small manufacturers in the boat building industry.  I would estimate
that about 95% of the boat builders in the US are not even aware of
these proposed regulations.  

The large number of small shops would make it very difficult and
expensive to test every individual model.  Grady-White Boats (GWB)
currently manufactures 20 different models, averaging less than 100
units, per model, per year.  Use of existing “standard writing
organizations”, such as the USCG and ABYC to establish acceptable
systems and installation guidelines will greatly simplify the process. 
Use of components tested (and labeled as meeting the EPA’s
requirements) will again ease the burden on the small businesses that
prevail in the marine industry.  Carbon canister volumes should be
specifically designated based on fuel tank capacity.

 Another benefit of the use of certified components and reference
standards is to eliminate the need for any record-keeping, reporting,
and paperwork associated with these regulations.  Government required
paperwork is a burden to all businesses, but especially the small
businesses. 

Canister Sizes for Larger, Non-Trailerable Boats

The larger boat models have a much higher fuel capacity than the average
size tanks the EPA has been testing.  GWB’s largest model is a 36’
boat with a total gasoline fuel capacity of 370 gallons.  Our 33’ has
350 gallons of capacity.  Our 30’s (three different models) hold
between 290 and 306 gallons.  Our 27’ and 28’ models (three
different models) have 205 gallon tanks.  Since most of these larger
boats are stored in the water the diurnal emissions are greatly reduced
when compared to the smaller, trailerable boats.  Diurnal temperature
swings experienced on the larger boats (with built-in tanks) that remain
in the water are much different than those of smaller boats stored on
trailers.  The required volume of carbon for these larger boats may be
less than needed for the smaller trailerable boats to control the
diurnal emissions.  Finding space to locate the proposed 14.8 liters of
carbon that would be required for 370 gallons of fuel becomes a
challenge in and of itself.  If this much is not really needed due to
reduced diurnal swings, allow flexibility in the rules to reflect the
reduced need.  Testing should be performed to establish the true
temperature swings experienced by boats stored in-water.

Most boats about 25’-26’ in length become more difficult to use as
trailer-boats due to the beam increasing to above 8’ 6”. Most states
require special permits to move these boats on the highways.  The USFWS
has a grant program that provides funding for infrastructure for
“non-trailerable, transient boats” and they designate boats 26’
and above as non-trailerable in this program.  (50 CFR Part 86.12)  This
grant program is called Boating Infrastructure Grant Program (BIG-P). 
The EPA may want to consider using these same guidelines to establish
the baseline for boats mostly stored in-water.

Per Component Cost Disadvantage

Another issue smaller businesses face is the pricing disadvantage of
small/low volume usage of components.  Larger companies building 40,000+
boats a year are going to be able to negotiate a better price per
canister (and other components) than the small builders purchasing less
than 2000-3000/ year.

Inaccurate Cost Evaluations

The proposal contains cost estimations that do not appear to be accurate
based upon our research.

  

Cost of hose configurations is too low.  All of the lengths stated as
“typical” in table 2-1 of the draft are much shorter than our
typical lengths.  About 25% of our 20 models are purchased with dual
tanks as standard and another 20% of the model line is offered with an
optional second auxiliary tank.  Averaging the total lengths of fuel
hoses across the model line gives us the following averages.  Models
with optional tanks were averaged with the main tank hoses only.

				GWB Avg		EPA Table 2-1

Fuel Fill hose- 			10.5’			5.8’

Fuel Vent hose- 		10.5’			7.5’

Fuel Supply hose- 		31.4’			6.5’

It is clear that the hose lengths used in the cost comparison are about
two to almost five times shorter than our actual average length.

The systems set up for the carbon canister test program in 2005 used
Racor fuel/air separator (Racor part # LG-50) that cost about $50 each,
not the $2 shown in the Draft cost estimates on page 16.

Carbon canisters for the tested systems installed on our boats last year
also required four clamps per tank at $0.279 each versus the two at
$0.20 each as shown in the EPA estimate.

Additional hose was required - 6’ of fuel vent hose per tank at $0.435
per foot.

We also used a piece of poly to cover the area in front of the
canisters.  The project boat used four square feet at $3.24 per SF.
Total cost of $12.96.  This was the method we chose for the test boat,
but every model will need some kind of hatch or coverboard allowing
access and a mounting surface or both.  None of this cost was addressed
in the EPA estimates.

Canister costs were estimated to be about $38 for a 100 gallon tank. 
Projected costs of the canisters given to us range from $25 to $200. 
The $25 figure assumes that every builder will use common sized
canisters and there will be only a few different designs offered
nationwide.  Design restrictions and larger tank capacities will more
than likely draw this cost up to approximately $80 to $150 per canister
based on our best estimate.  This is difficult to price accurately due
to unknown factors regarding canister volumes and space/design
limitations.

On larger boats, with offshore capabilities, most have dual fuel
tanks/systems.  On these models the total cost is doubled!

Molded Tank Costs

Current tank suppliers state the EPA cost projections of the proposed
treatment or coating is too low and that current technologies are
unproven.  Our molded tanks are 60 and 82 gallons each.

Drop box molding costs have been estimated to be about $5000 per mold by
the current tank molders, not the $1000 estimated by the EPA.  The
amortized cost per part is therefore five times higher than the EPA
estimate in the proposal.  These tanks are normally manufactured at a
volume of about 100 tanks per year.    

  

Cost of epoxy coatings are estimated at $6 to $7 per pound by the EPA. 
Tank molders estimate the current cost of the material at $12- $15 per
pound.  

Shipping cost per tank for this treatment is estimated at $0.30 to $1.00
per tank which is unreasonable considering the size of our current
tanks.  Currently, a letter costs $0.39 to mail in the USPS.  There is
no method to ship a 60 to 80 gallon tank for $1.00 or less.

The multi-layered system is not field proven in marine applications.  No
boat builder is currently installing multi-layered tanks.  According to
the one supplier who states they have designed a process to successfully
produce multi-layered tanks, the cost increase per tank is about 50% of
current tanks. This represents an increase for Grady-White’s per tank
cost of at least $70.  The current lack of tested and field-proven tanks
using new construction materials and methods requires flexibility and
careful consideration by the EPA for sufficient field testing.

Need to Develop New Plastic Materials

The small businesses (tank molders and boat builders) do not have the
clout or volume to push plastic resins/material design onto companies
such as Phillips or Exxon.  The USEPA needs to push the development of a
new material that will be cost equivalent to current materials or at
least very close.  This gap also shows the need to set a technology
review date in the future.  It is necessary to assure advancements are
occurring that will provide acceptable materials to be developed.   The
review should include consideration of the material’s cost,
feasibility, and the lead-time needed to make a conversion from present
materials.

 

Tooling Modification or Replacement 

One of the largest single expenses resulting from requiring the use of
carbon canisters is completely ignored by the EPA’s cost estimates-
tooling redesign or modification costs.   All fuel connections and
fittings are required to be readily accessible for inspection.  Any
additional components or connections created by use of canisters must
meet this requirement.  Molds (or “tooling”) will need to be
redesigned to accept some type of access door or hatch.  

Grady-White currently manufacturers 20 different models and there are
potentially 31 deck and liner molds that could require modification to
incorporate access.  This cost would be very high as modifications to
tooling are expensive and not very durable.  The initial cost and
long-term maintenance cost associated with extensive modifications need
to be added to the cost estimation.  

Flexibility should be built in to allow sufficient time to modify and/or
replace existing tools.  Many smaller builders will utilize a mold for
seven or more years before a redesign occurs.  Even large volume boat
builders will utilize tooling for at least five years before replacing
tooling with newer designs.  Small businesses will require flexibility
to work through these modifications/replacements without causing undue
financial hardship.

Thanks for the opportunity to provide input regarding the proposed
regulations.  It is critical for our business that we have a clean and
healthy environment.   I look forward to continuing to provide input to
the USEPA and would ask that you contact me if you have any questions.  
  HYPERLINK "mailto:jhardin@gradywhite.com"  jhardin@gradywhite.com  
Phone: 252 752 2111.

Sincerely,

Jim Hardin

Compliance Manager

Grady-White Boats, Inc.

PO Box 1527

Greenville, NC 27835-1527  

