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Whichever way round it is, the Bixters are making a good contribution to canal heritage - keeping alive a former carrying company and a manufacturer of traditional diesel engines. Good luck to them.

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Whichever way round it is, the Bixters are making a good contribution to canal heritage - keeping alive a former carrying company and a manufacturer of traditional diesel engines. Good luck to them.

 

Most definitely - they have worked on Tawny Owl twice. We like them

 

Richard

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This may be of interest to some regarding the old and new RCDs. Info obtained during another phone call to Mike Clarke BTW.

 

The old RCD didn't actually allow the purchase of a shell and then the owner finishing the fit out as a boat 'constructed for own use'. It had to be constructed entirely by the owner because otherwise the shell builder was obliged to supply a Part 3 completion certificate which would belie the claim that the craft was 'constructed for own use'. However, where this occurred the enforcement was lax so it never caught up with anyone. Similarly some people used the loophole of a 'replica craft' when using historic engines etc. Also, the 'owned and kept for 5 years before you can sell it' for craft constructed for own use had a bit of an anomaly in it, in that the date that the boat is 'first put into use' was the date that the shell was put into the water, not the date when the boat was completed. Apparently the new RCD is being drafted to tighten up on these loopholes.

It looks to me that if the enforcement is stiffened, as required by the other directive that I have mentioned before, then any loophole that might somehow allow continued use of heritage engines is going to disappear.

Roger

Having begun this topic in all innocence, it was never my intention to stir up such a debate...however, with reference to the above, and my intention to get a shell built and install an old diesel engine, where will I stand, vis-a-vis the RCD?

David

Or is this a bit far off topic?

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Having begun this topic in all innocence, it was never my intention to stir up such a debate...however, with reference to the above, and my intention to get a shell built and install an old diesel engine, where will I stand, vis-a-vis the RCD?

David

Or is this a bit far off topic?

It is on-topic as part of the general discussion that this thread has turned into. The situation is that the current RCD allows an old engine to be installed in a new shell. However, all the info that I can glean from the man who has fought for old engine exemption to be continued in the new RCD....and lost!!! is that this will not be possible under the new RCD. Quite when the new RCD will be in force and whether there is any grace period I haven't been able to get a handle on yet. Even when the new RCD is in force, being quite frank, it will take our Trading Standards people to enforce it and do they have the manpower? However, as described above, there is apparently a new directive already in force that requires member states to take much more seriously the matter of enforcement......forcing them to enforce, if you see what I mean and this is another unknown in the equation.

Personally, if I was doing the same as you then I would try to have my boat built as soon as possible to circumvent the later RCD and the enforcement stiffening directive but I realise that may not be a practicable proposal for all sorts of reasons.....finances and boat builder lead times to name but two.

Roger

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Roger

Many thanks for the reply, which pretty much confirmed my suspicions re the state of future regulations.

Hopefully we will be able to get a hull built over the winter.

 

Further to Roger's reply, I have now emailed the RYA on the new RCD vs vintage engine question to see what their views are. Their RCD expert is not available until next week and in any case they may just refer to Michael Clarke anyway as they dealt with him earlier on this I believe.

 

The RYA was, until recently, a UK approved RCD notified body but has decided to give this role up. I didn't know this and it came as a bit of a shock when I was googling around for RCD related snippets yesterday!

 

I have also spoken to some of the canal mags to see if they want to research the new RCD for their news pages bearing in mind that it was only recently "adopted" (voted in) in the EU Pariament on 9 Oct! Both WW and Canal Boat seemed quite interested in doing something.

 

Of course its probably far too late to save the situation in respect of keeping the old rules for vintage engines in new boats but it might be worth bringing a bit more publicity to bear.

 

Richard

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The text as written on the 9th October. Scarcely the doom and gloom trumpeted over the last few days. Clearly you can still fit a vintage engine to a pre 1950 design boat ,or replica of one. The rule regarding selling on a self build is the same. When it comes into force it will eliminate all of the Betas and Barrus engines etc as they will be clearly non compliant. If the final issue does permit the fitting of tier 3a engines in newer designs of boats (ie Betas in SM Hudson boats) it will automatically permit all the older designs of engines too. As I see it there is a way to go yet but a period engine in a period design hull remains absolutely fine. So if you have a hull that is a replica of an old design you can fit an old engine. If you have a modern floating skip you can't.. But then you can't have a tier 3a engine anyway. There is a way to go before the tier 3A engines disappear as they are the standard non road engine all over the EU. They are authorised under a different directive entirely. As for us we will continue supplying vintage engines to our sister organisation (Riveted Narrowboat Company) where the 1900 design puts us well into the exempted category.

 

 

This Directive shall not apply to the following products:

 

(a) with regard to the design and construction requirements set out in Part A of Annex I:
(i) watercraft intended solely for racing, including rowing racing boats and training rowing boats, labelled as such by the manufacturer; (ii) canoes and kayaks designed to be propelled solely by human power ▌, gondolas and pedalos; (iii) ▌ surfboards designed solely to be propelled by wind and to be operated by a person or persons standing; (iv) surfboards ▌ ; (v) original historical watercraft and individual replicas thereof designed before 1950, built predominantly with the original materials and labelled as such by the manufacturer; (vi) experimental watercraft, provided that they are not placed on the Union market; (vii) watercraft built for own use, provided that they are not subsequently ▌ placed on the Union market during a period of five years from the putting into service of the watercraft; (viii) watercraft specifically intended to be crewed and to carry passengers for commercial purposes, without prejudice to paragraph 3, regardless of the number of passengers; (ix) submersibles; (x) air cushion vehicles; (xi) hydrofoils; (xii) external combustion steam powered watercraft, fuelled by coal, coke, wood, oil or gas; (xiii) amphibious vehicles, i.e. wheeled or track-laying motor vehicles, which are able to operate both on water and on solid land; with regard to exhaust emission requirements set out in Part B of Annex I :
(i) propulsion engines installed or specifically intended for installation on the following products:
– watercraft intended solely for racing and labelled as such by the manufacturer; – experimental watercraft, provided that they are not placed on the Union market; – watercraft specifically intended to be crewed and to carry passengers for commercial purposes, without prejudice to paragraph 3, regardless of the number of passengers; – submersibles; – air cushion vehicles; – hydrofoils; – amphibious vehicles, i.e. wheeled or track-laying motor vehicles, which are able to operate both on water and on solid land; (ii) original and individual replicas of historical propulsion engines, which are based on a pre-1950 design, not produced in series and fitted on watercraft referred to in points (v) or (vii) of point (a); (iii) propulsion engines built for own use provided that they are not subsequently placed on the Union market during a period of five years from the putting into service of the watercraft; © with regard to noise emission requirements referred to in Part C of Annex I:
(i) all watercraft referred to in point (ii) watercraft built for own use, provided that they are notsubsequently placed on the Union market during a period of five years from the putting into service of the watercraft.

Edited by steamraiser2
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The text as written on the 9th October. Scarcely the doom and gloom trumpeted over the last few days. Clearly you can still fit a vintage engine to a pre 1950 design boat ,or replica of one. The rule regarding selling on a self build is the same. When it comes into force it will eliminate all of the Betas and Barrus engines etc as they will be clearly non compliant. If the final issue does permit the fitting of tier 3a engines in newer designs of boats (ie Betas in SM Hudson boats) it will automatically permit all the older designs of engines too. As I see it there is a way to go yet but a period engine in a period design hull remains absolutely fine. So if you have a hull that is a replica of an old design you can fit an old engine. If you have a modern floating skip you can't.. But then you can't have a tier 3a engine anyway. There is a way to go before the tier 3A engines disappear as they are the standard non road engine all over the EU. They are authorised under a different directive entirely. As for us we will continue supplying vintage engines to our sister organisation (Riveted Narrowboat Company) where the 1900 design puts us well into the exempted category.

 

Snipped the quoted RCD words - one read is generally enough!!

 

I agree with most of the words you say above but the bit you quoted from the 9th Oct new text is pretty much identical to the list of exclusions that have always been given in the 1994 RCD (for boats) and its 2003 amendment that brought in the first stage of engine emissions. In other words, they haven't significantly altered that bit.

 

It has therefore always been the case that pre 1950 historic boats and their true replicas can be fitted with pre 1950 engines and their true replicas. These have always been entirely exempt from the RCD in the same way that any new steam powered boat has and will continue to be.

 

I now see that your main business of supplying vintage engines is exclusively for such boats and you don't get involved with supplying them to "floating skip(!)" boat builders. Perhaps you're right then that MPS won't have a problem with the new RCD.

 

I believe that some people have hung their hat in the past on the concept that any narrow boat could be considered as a historic replica but I've read that this would be unlikely to be accepted in the case of a "floating skip". (Incidentally my as yet incomplete boat is based on a floating skip, a Colecraft one! It's OK for me!).

 

Under the 1994/2003 RCD, fitting a pre Jan 2005 engine (not 1950) in a new build boat was interpreted as acceptable in a document called the "emissions matrix". This two page document is still available to download from the BMF website here. It also shows that such an engine can be fitted in any new build craft, not just a historic pre 1950 replica.

 

I believe this document resulted from Michael Clarke's original negotiations with EU officials as an acceptable interpretation of the 2003 RCD amendment and it is this document which has now (presumably) become unacceptable under the 9th Oct enactment which has repealed the both the 1994 RCD and its 2003 amendment.

 

Clearly it is necessary to get further advice on this if anyone does want to install an existing pre 2005 engine in a new build boat and still expect it to become fully "new RCD" compliant after the "bringing into force" date (whenever that is).

 

It does seem to me that not many folks are aware of this.

 

Re the continuation of the RCD exemption that applies when any boat is "built for own use" provided it is not sold by the builder for 5 years from first use - you say that it is still the same. Indeed the words are the same as in the old RCD but as Roger (Abion) has commented in post #67 it may now be interpreted that where a commercially built shell is bought (and has an Annex IIIa DoC issued) and then fitted out by the DIY builder, this may no longer be considered as building for own use.

 

I have asked the RYA to advise me on this point as well.

 

Richard

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"Re the continuation of the RCD exemption that applies when any boat is "built for own use" provided it is not sold by the builder for 5 years from first use - you say that it is still the same. Indeed the words are the same as in the old RCD but as Roger (Abion) has commented in post #67 it may now be interpreted that where a commercially built shell is bought (and has an Annex IIIa DoC issued) and then fitted out by the DIY builder, this may no longer be considered as building for own use."

 

Above taken from Richard's post 112

 

So if we have a hull built by a quality builder, known for making "traditional" boats, have it insulated, lined, "old" engine fitted, wired, portholed and a few bulkheads put in, will that be acceptable?

 

Yours

Confused of Burton

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The text as written on the 9th October. Scarcely the doom and gloom trumpeted over the last few days. Clearly you can still fit a vintage engine to a pre 1950 design boat ,or replica of one. The rule regarding selling on a self build is the same. When it comes into force it will eliminate all of the Betas and Barrus engines etc as they will be clearly non compliant. If the final issue does permit the fitting of tier 3a engines in newer designs of boats (ie Betas in SM Hudson boats) it will automatically permit all the older designs of engines too. As I see it there is a way to go yet but a period engine in a period design hull remains absolutely fine. So if you have a hull that is a replica of an old design you can fit an old engine. If you have a modern floating skip you can't.. But then you can't have a tier 3a engine anyway. There is a way to go before the tier 3A engines disappear as they are the standard non road engine all over the EU. They are authorised under a different directive entirely. As for us we will continue supplying vintage engines to our sister organisation (Riveted Narrowboat Company) where the 1900 design puts us well into the exempted category.

 

You are very confident of your facts as they are trumpeted but can I remind you that Tier 3A (or any Tier emissions regs for non road engines for that matter) are purely a United States EPA (Environmental Protection Agency http://www.epa.gov/otaq/nonroad-diesel.htm) regulation. It applies to all US states that do not choose to apply the stricter CARB (California Air Resources Board http://www.calepa.ca.gov/About/History01/arb.htm) limits which applies to California (surprise, surprise) and a few other states that choose to apply the tougher standards....not many, but some.

The applicable regulation in Europe is called Stage X (choose the applicable number). It is true that the two (Tier and Stage) have been moving closer together under pressure from engine suppliers who, naturally, want a common standard all over the world if possible, but aren't totally aligned yet and won't be even at Tier 4/Stage 4 level I understand.

 

I haven't had chance to study the rest of your quoted RCD detail yet but it looks very much like at first glance a straight snip from the 2011 new RCD PROPOSAL document. This is a document that is used as the basis for discussion and argument before the final RCD proposals are agreed by the Commission and then put before the Parliament. I am taking further advice from someone who knows a lot more about the subject on the rest of your trumpeting.

Roger

"Re the continuation of the RCD exemption that applies when any boat is "built for own use" provided it is not sold by the builder for 5 years from first use - you say that it is still the same. Indeed the words are the same as in the old RCD but as Roger (Abion) has commented in post #67 it may now be interpreted that where a commercially built shell is bought (and has an Annex IIIa DoC issued) and then fitted out by the DIY builder, this may no longer be considered as building for own use."

 

Above taken from Richard's post 112

 

So if we have a hull built by a quality builder, known for making "traditional" boats, have it insulated, lined, "old" engine fitted, wired, portholed and a few bulkheads put in, will that be acceptable?

 

Yours

Confused of Burton

My understanding is that 'replica' has been misused to mean a steel narrow boat that is a steel narrow boat because similar 'styled' boats were used originally. The original RCD (never mind this one) didn't really mean that any narrow boat was sufficient as a 'replica', it was meant to apply to real, historically correct, replicas of early craft.

I don't think that any of the present craft built by builders who do produce really good looking traddy boats (Roger Fuller, the Wains, Norton Canes to name but a few) will actually be allowed as a replica. My understanding is that the definition of 'replica' is going to be tightened up to close the loophole that has been used, but I have no more detail than that at the moment.

Roger

Edited by Albion
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"Re the continuation of the RCD exemption that applies when any boat is "built for own use" provided it is not sold by the builder for 5 years from first use - you say that it is still the same. Indeed the words are the same as in the old RCD but as Roger (Abion) has commented in post #67 it may now be interpreted that where a commercially built shell is bought (and has an Annex IIIa DoC issued) and then fitted out by the DIY builder, this may no longer be considered as building for own use."

 

Above taken from Richard's post 112

 

So if we have a hull built by a quality builder, known for making "traditional" boats, have it insulated, lined, "old" engine fitted, wired, portholed and a few bulkheads put in, will that be acceptable?

 

Yours

Confused of Burton

 

Agree about the "confused" - I thought I was pretty good at the RCD until a few days ago.

 

Thats why I have asked the RYA to advise further. The worry is that even among RCD professionals there can be conflicting views!

 

It certainly was OK to do what you have planned and perhaps it may still be until the new RCD "grace period" comes to an end in approx 2 years time.

 

I am a bit further down the road and feel I must now work faster to get it all finished and documented.

 

Incidentally, seeing Roger's (Albion) comment about which version Steamraiser was quoting, I have certainly read the entire "adopted" new RCD dated 9 Oct 2013. The whole thing is available on the European Parliament website here.

 

I can recommend a quick read if you are an insomniac!

 

It does look as though Steamraiser was quoting the latest words but I agree with Roger that interpreting what a historic replica is may not be straightforward.

 

Richard

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Incidentally, seeing Roger's (Albion) comment about which version Steamraiser was quoting, I have certainly read the entire "adopted" new RCD dated 9 Oct 2013. The whole thing is available on the European Parliament website here.

Thanks Richard, I could not find that adopted document but now have it. I'm going to compare it with the proposal document to see if I can spot any changes. I need a sedative and this could be the answer clapping.gif

Roger

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A few more comments regarding the RCD and the determination of some of you to think that this is the end of the world as we know it !

 

1, The EU has a problem with the sneaky importation of non 3A engines from India and China. It has never been an issue in the UK but is a big issue in the Netherlands and Belgium where these non compliant motors are openly advertised and traded. The new RCD is designed to eliminate this, not that it will, as many of the traditional boats in those countries claim to be "commercial" and therefore exempt. They use this cop out in the same way that we hide behind the old RCD exemption. It will not be enforceable over there as there is no will do so. The only country enforcing the existing regulations is the UK although it is only paying lip service to it.

 

2/ Yes the 3A specification is a US one, their standards have been used as the bench mark for most engine manufacture for years. In the same way vitually all European standards for most things are based on the British standards simply because our system was the most practicable. These are now being degraded as many of our EU partners cannot meet them. To arbitrarily ban 3A compliant engines is a global WTA issue and no one is going there just yet. They will eventually and then we can all look forward to turbocharged ECU managed turbo diesels in our boats. None of the new engines currently supplied for use in narrowboats will be compliant let alone vintage ones. Bye bye most of the current engines we love and loathe! In reality production of the older designs will only move to developing countries.

 

3/ The comment that the premier boat builders who build replica boats will not pass the "replica" test is a very large statement. They are building traditional boats in a traditional manner. It would take a lengthy court process to say they don't. Who is going to pursue that ?. This would also be true of the traditional boats of all the other countries too. A minefield once national cultures are involved. The only way they could do this would be to have a cut off date for any "replicas" which this new RCD does not have.

 

This would bring us on to the next tier of cop outs. You would see a growing industry in refurbishing older boats, lots of " experimental" boats and an increasing number of "commercial" boats as well as many new clone Joshers etc built to individual specifications which is also allowed. You may also see old boats bought for their registration with a virtually new craft being built from the ashes of the old one. No type approval needed. You could also fit a shiny new compliant engine on a subframe to power your boat while it goes through its CE hoops and then swap it out for your fav Gardner cool.png I can hire you one if you like!

 

What won't be allowed is the production line manufacture of non compliant boats. As virtually no one is doing that at the moment I can't see that being too much of an issue. If the past is anything to go by the only drivers for serious enforcement will be tax revenues, try sailing a boat abroad while full of red diesel etc.

 

4/ What I do believe is that there is a risk of our traditional narrowboats being degraded by the unintended consequences of a well meaning bit of EU legislation.We all need to to make a concerted effort to see that our interests are protected. It isn't a fatal blow yet but next time?

 

 

We do an increasing amount of sea going engines these days currently a Kromhout for a Dutch flagged barge. Their view? They don't care nor does their government as it is national heritage not business.

 

At least Dopey David is giving us us an EU referendum before long. With the polls suggesting 70% wanting out it is not likely we need to worry overly !

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In the RCD annexe on emissions it talks about engine life for diesels being 480 hours or 10 years, which ever comes sooner. And they wonder why people laugh at EU regulations.

Yes you are going to have to change your engine every 480 hours.........................................NO, NO, NO I'm only joking laugh.png

The ridiculous hours have always been a part of the regulation but, after presumably considerable technical consultation, they still have it. Mind you I am talking about European civil servants and politicians here so perhaps we shouldn't be surprised.

Roger

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Yes you are going to have to change your engine every 480 hours.........................................NO, NO, NO I'm only joking laugh.png

The ridiculous hours have always been a part of the regulation but, after presumably considerable technical consultation, they still have it. Mind you I am talking about European civil servants and politicians here so perhaps we shouldn't be surprised.

Roger

 

 

The Scania diesels put into the newest RNLI lifeboats are compliant for the first 250 hrs and then never again. Good job they are exempt or else they would have to build "replica" lifeboats clapping.gif

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In the RCD annexe on emissions it talks about engine life for diesels being 480 hours or 10 years, which ever comes sooner. And they wonder why people laugh at EU regulations.

 

As enthusiastic continuous cruisers 480 hours is less than 6 months for us!

We bought our boat second hand after a fit out from the previous owner. I was very slightly worried that it did not have an RCD which might be an issue if we ever had to sell, but I am now feeling that boats that are outside the RCD system may be more desirable!

 

............Dave

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As enthusiastic continuous cruisers 480 hours is less than 6 months for us!

We bought our boat second hand after a fit out from the previous owner. I was very slightly worried that it did not have an RCD which might be an issue if we ever had to sell, but I am now feeling that boats that are outside the RCD system may be more desirable!

 

............Dave

A while ago I talked the subject of hours of cruising per day over with a neighbour of mine, who is like me, not getting any younger. In the past we would boat from dawn to dusk, and reckon 480 hours could last as little as 6 weeks of summer cruising.

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