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Old 28 April 2017, 10:46   #11
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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;

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Old 28 April 2017, 10:47   #12
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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?
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Old 28 April 2017, 11:29   #13
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Quote:
Originally Posted by Brage View Post
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.
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Old 28 April 2017, 12:38   #14
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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.
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Old 28 April 2017, 13:03   #15
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Jeeze - two bald men arguing over a comb!

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I'm "ash-blonde" (sometimes mistaken for grey)......and I could always dye it if need be.
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Old 28 April 2017, 13:21   #16
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Just make sure your hair dye complies with Regulation (EC) No 1223/2009
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Old 28 April 2017, 15:29   #17
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)......and I could always dye it if need be.
I think you misheard them!
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Old 29 April 2017, 05:25   #18
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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...

Quote:
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...
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Old 29 April 2017, 14:19   #19
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+1

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Old 29 April 2017, 16:45   #20
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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.
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