Jeff P. Jordan

Jeff Jordan Mitigating Boat Environmental Damage - Page 1 of 8 Mitigating Boat Environmental Damage in EPA Areas of Air, Climate Change, Ecosystems, Health, Sustainability, and Water I. Introduction Recreational Boats present opportunities in the EPA focus areas cited above.      They emit 1% total vehicle CO2, projected to rise to 1.2% by 2040. Over 99% of boats in service exceed current CO, NOx, and VOC limits for new inboard boats. Propeller related injuries are a poorly documented but significant human health/safety issue. Marine mammals, turtles, coral, seagrass, and other marine life also suffer propeller injuries. Discharge flows from current propellers and water jets disturb the bottom, polluting the water and destroying habitat for marine life. “Larval and juvenile fish can be killed directly by boat propellers and propeller wash. Spawning or nesting fish can be disturbed, and propeller wash . . .” from https://www.epa.gov/sites/production/files/201509/documents/2001_10_30_nps_mmsp_section2.pdf There are technologies and design methods available to significantly mitigate all the above, while offering similar benefits in commercial and military boat applications both manned and unmanned. The use of such mitigating technologies and methods in recreational boats is not encouraged by the current regulatory regime. Continuing on the same path will only make the situation worse. The Department of Energy EERE Vehicles Division declines to take any funding interest in the energy efficiency of boats, taking the position that vehicles with wheels are a better use of funds. (See Correspondence attached as Appendix 2.) We offer a regulatory regime here to achieve a 50% or greater reduction in 2040 Recreational Boat CO2 emissions by 1) raising standards for repowering existing boats and 2) requiring/inducing the adoption of new hull and propulsion technologies through CAFE and other strategies, which have been used successfully in automobile regulations. We also suggest an opportunity for the EPA to fund a demonstration of the current state of these technologies, which have the potential to not only reduce CO2 emissions by 50% and but also to mitigate all of the boat-related environmental problems cited above. II. Analysis of Recreational Boating Regulation in View of the “Paris Agreement”     Recreational boats consume 140,000 barrels/day oil equivalent @ .475 tons CO2/barrel or 665,000 tons of CO2/ day, 1% of US transportation fuel, more than busses. (See Appendix 1) Current EPA regulation of boats fall far short of CAFE automobile standards and extends the useful (or rather, counterproductive) life of old, inefficient, polluting boats indefinitely. Cars and trucks already get 10x better fuel mileage than recreational boats, new or used. This problem is inescapable, as boats will be the very last vehicles to be electric, due to the prohibitive weight and cost of the required battery capacity at 5-10x the requirements for cars. Jeff Jordan Mitigating Boat Environmental Damage - Page 2 of 8 1. Effect of current regulation on NEW boat sales EPA’s current standards encourage fuel-inefficiency. The Premier 310 Dodici below is fully compliant with current EPA grams/kwh regulations and is in one of the fastest growing new boat market segments. It can go 57 mph using 72.3 gallons per hour, and the best it can do at any cruising speed is 1.6 mpg. http://www.boattest.com/review/premier/3516_310-dodici As shown above, while marine engines have been getting more efficient, they are being used less efficiently in new boats. Boat buyers are far more interested in performance than in fuel economy, and the EPA’s current g/kwh efficiency standard enables this (COP21 dysfunctional) behavior. 2. Effect of current regulation on USED boat sales Used boat sales now dwarf new boat sales. Today, more than 9 out of 10 boat buyers buy used boats. In sterndrive boats, still the most popular family boat type, over 9.5 out of 10 buy used boats. 150,000 of these boats were sold new in 1989, tapering down to 70,000 in 2007, just before the Great Recession and the 2010 imposition of catalytic converters. In 2015, only 12,000 new sterndrive boats were sold into a US registered fleet of 1.6 million, so it would take 133 years to displace the existing boats. 3. Why used sterndrive boats dominate sales A. New outboard boats, like the one shown above, are more competitive on a performance/cost basis. This is partly because they do not carry the reported $2500 additional cost of emission control technology required in new sterndrive boats, and partly due to the improved technology in outboard motors and related innovations in outboard boats. B. EPA regulations require new sterndrive and inboard boats sold in 2010 and later years to have catalytic converters and closed fuel systems. These systems must be maintained, which buyers see as an additional cost to the already high maintenance costs of a boat. C. 2009 and earlier boats may have their engines rebuilt or replaced forever (either with old carbureted engines or with new high-performance engines) without ever requiring the costs associated with catalyst and closed fuel systems. D. Buyers see no performance innovation in new sterndrive boats to justify their higher cost. Jeff Jordan Mitigating Boat Environmental Damage - Page 3 of 8 Just how bad is it? And how bad is it going to get?  Here is the latest industry news: 4. The Age of Vessels is Increasing. “. . Peter Houseworth, director of client services at Info-Link, says this aging inventory goes back to boats built in the 1960s and 1970s; those boats were built in such a way that they could effectively be used “forever” if maintained properly. “They don’t expire, given that you can repower them.” In current years, the boating industry is adding roughly 235,000 units to a fleet of 11 million. “. . .so we’re adding about 2 percent to the fleet every year. Basically, the size of the fleet is flat to declining slightly, but it’s hard to influence if you’re only adding 2 percent every year,” From Boating Industry’s Market Data Book 2016 www.BoatingIndustry.com.  Since this sea of used vessels can be legally repowered forever with inefficient systems, how can their 665,000 tons of CO2/ day effect on the environment ever be reduced? III. Regulations Required to Meet COP21 Paris Agreement Expectations There is technology available that addresses all the issues raised above in one package. Its acceptance requires EPA regulation of boat carbon emissions similarly to the Agency’s regulation of automotive carbon emissions with the current Corporate Average Fuel Economy (CAFE) standards for automobiles. 1. Prospective New Boat Regulation For new boats the EPA could establish a series of classes of boats based on size and function, establish a mpg requirement for each class, and use a CAFE scheme like the one for automobiles. Such a CAFE scheme would also result in more efficient boat hull forms and more efficient propulsions. 2. Prospective Used Boat Regulation Even a phased-in CAFE for new boats will make new boats even less competitive in terms of performance/cost, which will again have the effect of driving down new boat sales and extending the life of pre-2010 boats. The only way to prevent these unintended consequence is to impose additional regulations on the sea of used boats. Jeff Jordan Mitigating Boat Environmental Damage - Page 4 of 8 Such regulations are inescapable if there is to ever be a meaningful reduction in boat carbon emissions. 3. Used-boat regulations suggested by market and COP21 Paris Agreement realities A. Require that all gas marine replacement motors be electronically controlled and fuel-injected to progressively eliminate the use of carburetors in boats, which would be justified by reductions in C02, CO, VOC, and NOx emissions, as well as by the prevention of explosions and fires due to gasoline leaks from the carburetor into the bilge. The vast majority of sterndrive and inboard boat engines now in use are carbureted. B. Provide a “Cash-for-Clunkers”-like payment, a tax credit, or other incentive to encourage the replacement of existing carbureted engines and inefficient propulsion systems with a more efficient boat propulsion system. This would be justified by reductions in C02, CO, VOC, and NOx emissions and by eliminating the exposed propeller to mitigate the “Propeller-related Environmental Issues” mentioned above and detailed below. (Such a system would include/ require an electronically controlled, fuel injected engine, as is universally used in new automobile motors and in new inboard and outboard boat motors. It would also include a more efficient means of converting the motor’s shaft power into thrust force for propelling the boat. Such systems would be tested/certified by the EPA to qualify for such tax credits.) IV. Other Boat Propulsion-Related Environmental Issues Demanding Mediation: 1. Human Health and Safety. Open propeller drives on boats are about the only device in common use that maims or kills people around it. If a situation like this were found in a factory, OSHA would not allow it and would require immediate remediation to mitigate the hazard. 2. Protection of Marine Life. Injuries to marine mammals, sea turtles, fish, coral, sea grass, and other marine life also commonly result from open propeller drives. 3. Pollution of navigable water. Propeller drives are known for disturbing the bottom, which releases pollutants into the water and destroys eggs, fry, and habitat of marine life. V. Regulatory Benefits Summary The proposed regulations are an opportunity consistent with the COP21 Paris Agreement for the reduction of boat carbon emissions. They will also be an opportunity to eliminate propeller injuries to people, wildlife, and water quality. We are using the values in the projected 2020 column of Appendix 1: U.S. Energy Information Administration | Annual Energy Outlook 2016, Page A-17, for our statement at the top of this White Paper. Note that Recreational Boats are projected to grow from 1% to 1.2% of transportation fuel between 2020 and 2040. We believe that the forecast 1.2% could be cut to 0.6% or less and 2040 recreational boat CO2 emissions from 818,000 tons of CO2/ day to 414,000 tons of CO2/ day. Appendix 2: the U.S. Department of Energy’s Office of Energy Efficiency and Renewable Energy (DOE|EERE) Response confirms that DOE has no current interest in reducing boat emissions. This leaves the EPA as the funder of last resort. Jeff Jordan Mitigating Boat Environmental Damage - Page 5 of 8 VI. Demonstration of Technology to Support the Proposed Regulatory Regime 1. There is a 2:1 variation in fuel consumption of new boat models of similar size and weight using the same propulsion system. If all boats were optimized to conform to a CAFE standard, the average fuel consumption/CO2 emissions mileage might reasonably be expected to be reduced from 1.2 to 0.8 or about 25%, based on this summary from https://boatfuelconsumption.com/fuel-economy-of-20-24feet-boats/. 2. Even the best of the boat propulsion systems in the above are far from optimized, because they are still using propeller and waterjet systems that are not dynamically optimized under computer control. New Boat Engines are reasonably efficient, but significantly (typically 20%) less efficient at cruising speeds than they would be if they were efficiently loaded at their most common operating rpm points, as they are in automobiles with electronically controlled transmissions. 3. The loss in engine efficiency noted in 2 above is generally smaller than the loss that results from the sub-optimal conversion of engine shaft power to thrust. Using a fixed propeller pitch and diameter for the typical 0 -50 mph range of operation requires about 30% more power to produce the required thrust at 30 mph cruising speed, compared to the ideal propeller for that speed. In fact, such fixed propeller is relatively inefficient at all operating speeds. Fixed water jets are even less efficient over common ranges of speeds and loads than are propellers. 4. Eliminating the compounding losses of both the inefficient shaft power generation and the inefficient conversion of power to thrust would result in using only 56% of the fuel now required to generate the necessary thrust. Jeff Jordan Mitigating Boat Environmental Damage - Page 6 of 8 5. If an efficient boat hull form with friction reducing coating only requires 75% of the currently required thrust (Item 1 above), and the thrust can be produced with 56% of the fuel (Item 3 above), the total boat fuel required would be only 42% of what is currently required. CO2 would be similarly reduced. VII. Opportunity to Fund a Demonstration Boat The EPA has an opportunity to fund a demonstration boat that cuts fuel consumption and carbon emissions to 50% of the current average and eliminates propeller injuries to people, marine life, and water quality. 1. The hull forms and coatings to reduce hull resistance are already available for purposes of this demonstration. 2. The propulsion technology has been developmentally prototyped and can be optimized for this project with current computational fluid dynamics software and related computational methods. Such technology has been documented in four US Patents, peer-reviewed technical papers, and marine industry magazine articles, for example:       American Society of Naval Engineers (ASNE Day 2015) – Presented paper on propulsion and computer simulation for sustainable high speed boats and ships Marine Propulsion Magazine (UK) – IntelliJet nominated by editors for short list of Innovation Award Royal Institution of Naval Architects (RINA) –– Article published in July/August issue of Ship & Boat International Office of Naval Research — presented Poster on Electronically Controlled Marine Jet Propulsion at forum on Expeditionary Warfare: The Amphibious High Water Speed Challenge Cleantech Accelerator Program, Pacific NW Region – Accepted into program in May, 2015 and graduated in October, 2015. Cleantech Alliance Article – Boats: Technology Laggards of Transportation Industry Demonstrations videos and additional information are available at www.Power.iiJet.com. 3. The effect of this demonstration could be similar to the Volvo drive across the US in their “smog-free” car to demonstrate the first 3-way catalytic converter. Such demonstrations remove the uncertainty about the achievability of the desired result and reduce the fear-of-change factor. 4. The ROM cost of this demonstration is $1,400,000. Thanks for your consideration. Jeff Jordan- www.power.iiJet.com-LinkedIn Jeff Jordan Mitigating Boat Environmental Damage - Page 7 of 8 Appendix 1: U.S. Energy Information Administration | Annual Energy Outlook 2016, Page A-17 Jeff Jordan Mitigating Boat Environmental Damage - Page 8 of 8 Appendix 2: U.S. Department of Energy EERE Vehicle Technologies Office Response From: VTO- Date: Tue, Nov 8, 2016 at 5:54 AM Subject: 2016_Corr1719_Jordan_final To:-- Dear Mr. Jordan: Thank you for your October 28, 2016 e-mail to the U.S. Department of Energy’s Office of Energy Efficiency and Renewable Energy (DOE|EERE) regarding energy efficient boating technologies and your interest in their potential inclusion in our research and development (R&D) portfolio. The Department is very interested in the technical and economic justification for the addition of new technologies and transportation sectors to our portfolio and appreciate your interest in your ideas on decreasing fuel consumption and greenhouse gas emissions in the transportation sector. The Department periodically receives such requests each year and we review these against our available funding, current administration goals and objectives for DOE, and the overall potential for fuel savings and greenhouse gas reductions. We must justify changes in our program to senior DOE management as well as Congressional authorities. With regard to the recreational boat sector, the Department agrees that worldwide greenhouse gas emissions agreements will eventually push this sector to reduce fuel consumption, as your white paper posits. However, as the 2016 Annual Energy Outlook from DOE’s Energy Information Administration (EIA) notes, the recreational boat sector will represent only 1.2 percent of the total energy use in its 2040 reference case. Given the limitations of our vehicles program R&D budget, we cannot justify applying our limited funds to the recreational watercraft sector – where we may only be able to reduce overall transportation fuel use by fractions of a percent; instead of our current focus for on-road transportation in the light-duty and heavy-duty sectors –with better opportunities to reduce fuel use by significantly more. Considering our current funding levels and the continued high fuel use in the onroad vehicle sector, the Department does not see a pathway to justifying recreational marine R&D, particularly in light of existing goals and objectives and competing priorities that we must address. We encourage you to review EERE’s yearly funding opportunity announcements (FOAs) for opportunities to present your ideas as a formal proposal. Please visit www.eere.energy.gov and select the “financial opportunities” tab to follow the links to further information about these funding opportunities. Our “Office-wide” FOA often includes an open topic for new ideas not directly tied to our roadmaps, to which you might consider submitting your ideas. You may also wish to consider how increases in recreational boat efficiency could translate to local emissions reductions, and how that could be of interest to state and local agencies, such as your State Energy Office and other local grant programs established for the purpose of investing in your local energy economy. We appreciate your taking the time to contact the Department of Energy, and encourage you to continue your contributions to the reduction in transportation fuel use through your work. Sincerely, Roland M. Gravel, Technology Development Manager, Vehicle Technologies Office