EU boundless stupidity strikes again.

[Last Tango]

Some new "Directives"

Changes to Recreational Craft Directive | Hints and Tips | Cruising Tips | Knowledge & Advice | Knowledge & Advice | RYA

[John Kennett]

Why is this boundless stupidity?

It doesn't seem entirely unreasonable that if you make significant modifications to a boat that is required to comply with the RCD, the modifications need to comply too.

[Andy_Rs600]

Looks like fun, but unlikely to affect RIB owners unless you change from inboard to outboard, or add/remove water jets.

[Last Tango]

Or fit a 15 year outboard that doesn't conform to current emission regulations
or a curburated 2 stroke outboard engine to anything.......

[John Kennett]

I doubt that changing the outboard would count as a "Major Craft Conversion".

As far as I'm aware, other than specifying max weight and power, the choice of outboard isn't affected by the RCD anyway.

If you were to change an onboard diesel to onboard petrol, or outboard to onboard, then that would probably fall under the new regs. Looks like it's an inspection to check the conversion has been done properly, which would be handy to have anyway if you ever wanted to sell it.

[Last Tango]

Originally Posted by John Kennett

I doubt that changing the outboard would count as a "Major Craft Conversion".

As far as I'm aware, other than specifying max weight and power, the choice of outboard isn't affected by the RCD anyway.

The reference "and environmental requirements laid down in this Directive" makes me think it's further reaching than that.

[willk]

Jeeze - two bald men arguing over a comb!

It's not really going effect the UK much in a year or so....

[John Kennett]

Originally Posted by Last Tango

The reference "and environmental requirements laid down in this Directive" makes me think it's further reaching than that.

I suspect that you may be the purveyor of fake news in this instance, but let us know if you find out anything more definite either way

[Iron Dials]

Article 50! Just sayin'

[John Kennett]

Originally Posted by willk

It's not really going effect the UK much in a year or so....

That remains to be seen. And maybe we'll get our red diesel back, but I doubt it. Anyway, not all of our members reside in the UK so it may affect them

We're straying towards forbidden territory now, so tread carefully.

[Brage]

The new directives will have next to non influence on RIB or SIB owners.

Article 3 section 6 and 7 states:

(6)
‘major engine modification’ means the modification of a propulsion engine which could potentially cause the engine to exceed the emission limits set out in Part B of Annex I or increases the rated power of the engine by more than 15 %;
(7)
‘major craft conversion’ means a conversion of a watercraft which changes the means of propulsion of the watercraft, involves a major engine modification, or alters the watercraft to such an extent that it may not meet the applicable essential safety and environmental requirements laid down in this Directive;

Cheers

[willk]

Originally Posted by John Kennett

We're straying towards forbidden territory now, so tread carefully.

While almost on tippytoes, might I just highlight the last para of the RYA notice:

"NOTE - Directive 2013/53/EU has not yet been transposed into law in England and Wales, despite a requirement to do that before 18 January 2017. As a result, the RYA advice above is based on what the Directive states. Whilst it is anticipated that the Directive will be implemented without any material changes, this cannot be guaranteed. "

I don't imagine there will be a sudden rush to "transpose" this Directive now, hmmm?

[Last Tango]

Originally Posted by Brage

The new directives will have next to non influence on RIB or SIB owners.

Article 3 section 6 and 7 states:

(6)
‘major engine modification’ means the modification of a propulsion engine which could potentially cause the engine to exceed the emission limits set out in Part B of Annex I or increases the rated power of the engine by more than 15 %;
Cheers

Their interpretation of a ‘major engine modification’ includes a 15% increase in power.
That, I feel, could effect RIB users. There's a lot of restoration projects going on that could fall foul of this.

My original beef about this is that these directives should be "evidence based"
Has there been many accidents attributable to "modified RCD compliant" boats and is this going to prevent them? I'm more inclined to see this as the thin edge of the "Whole Vehicle Compliance" wedge that would make any sort of modification, customer specification or upgrade an issue.

[Brage]

I agree. The 15% limit could effect RIB and SIB owners. However theres no way anyone can control this regulation, so its ineffective.

The main "winners" is probably companies producing RIBs within the EU. China RIB`s are probably out. The directives propose is probably more protectionism than Saftey.

[Last Tango]

Originally Posted by willk

Jeeze - two bald men arguing over a comb!

.

I'm "ash-blonde" (sometimes mistaken for grey)......and I could always dye it if need be.

[Iron Dials]

Just make sure your hair dye complies with Regulation (EC) No 1223/2009

[willk]

Originally Posted by Last Tango

)......and I could always dye it if need be.

I think you misheard them!

[Poly]

Originally Posted by Last Tango

Their interpretation of a ‘major engine modification’ includes a 15% increase in power.

That, I feel, could effect RIB users. There's a lot of restoration projects going on that could fall foul of this.

i think you are misinterpreting engine modification with engine replacement. All new engines are RCD compliant, so fitting a new engine isn't going to be an issue. Restorations fitting old school 2 strokes are often on boats that were never RCD compliant anyway (ex commercial vessels).

You'd only run into theoretical issues if you were blatantly upgrading the engine (rather than replacing it). And even then, given the existing exemptions in the RCD for home built, prototype and race boats it only seems likely to be an issue when you want to sell it on...

My original beef about this is that these directives should be "evidence based"

Has there been many accidents attributable to "modified RCD compliant" boats and is this going to prevent them? .

You are misunderstanding the purpose of the directives. (And ignoring that the engine parts of the directive are mostly more concerned with the environment than safety). The aim is not to ensure there are only safe boats, but rather to ensure that there are common rules for selling boats. By stopping each country making up its own rules you have a theoretical 12x bigger market for your boat (and potentially a similar bigger number of boats to choose from for its replacement). If the reality is you will sell it only in the U.K. then as you know the existing RCD is not actively policed and only ever seems to raise its head in maib reports. Private sales for refurbished boats in the UK are unlikely to be affected in reality, brokers might do something for their money for once, but I suspect not for boats where there has just been a simple engine change. People selling to folks in mainland Europe where they are much more interested in paperwork for boats might have more issues...

[Brage]

+1

Cheers

[Last Tango]

Originally Posted by Poly

i think you are misinterpreting engine modification with engine replacement. All new engines are RCD compliant, so fitting a new engine isn't going to be an issue. Restorations fitting old school 2 strokes are often on boats that were never RCD compliant anyway (ex commercial vessels).

My last boat was bought new in 2013 (RCD Compliant). I fitted a 2004 "old school" 75hp Mercury and put it into use myself.

I am not interpreting the directive, the RYA are, and they state

"This means that any CE marked vessel* that undergoes a Major Craft Conversion must undergo a Module PCA assessment before being placed back on the market or put into service (whichever is the earlier). The legal responsibility for this is placed on the person who is placing the vessel back on the market or putting it back into service after the Major Craft Conversion has been carried out".

I could therefore not have lawfully done this under this new directive even with a Module PCA assessment and I can imagine what the costs involved in that would be.

I agree, you're very unlikely to get caught or confronted over it so, we just choose which rules we're going to abide by and which ones we're going to ignore and, that we can get away with this, demonstrates it can't be policed or enforced and just confirms its pointless stupidity.