We aren’t close to full restoration.
Over the last six weeks, I’ve had a productive dialogue with Owen Doherty, an Associate Administrator at MARAD regarding the methodology MARAD is using for calculating the restoration of sea year. He was responsive to my questions and I appreciate his candor. In this post, I will describe MARAD’s methodology and then explain why it does not present a fair picture of the restoration of sea year.
In order to report about the restoration of sea year, MARAD is using a “benchmark year” (my term) that began with the commencement of A-split sea year in November 2014 and ended with the conclusion of B-split sea year in November 2015. Thus, although this does not reflect a calendar year, it is designed to capture one full sea year for the equivalent of two full classes at the Academy. MARAD then determined the number of actual sailing days that Academy midshipmen received by company during that benchmark year. It did not count days on federal ships (USN, MSC, USCG, NOAA, etc.) but it did include days on ROS ships (government-owned ships in a laid-up reserve operating status with crews from private commercial shipping companies providing maintenance). The total number of sea-days in this benchmark year was 47,182. MARAD originally developed this metric so that it could figure out which companies offered the most sea-days and focus on those companies first during the Shipboard Climate Compliance Team (“SCCT”) approval process.
When a company is approved by USMMA based upon the SCCT recommendation, MARAD takes the number of sea-days that the company provided to Academy midshipmen during the benchmark year and considers that number of sea-days to be restored. Thus, if XYZ Shipping Company had provided 5,000 actual sea-days to Academy midshipmen in the benchmark year, then MARAD considers those 5,000 sea-days to have been restored. (MARAD recognizes that a company may not be operating the same ships presently that it operated in the benchmark year. The sea day count is at the company level. The number of vessels within a company may have changed; but that change is not accounted for using this methodology.)
There are now nine SCCT approved companies (although only eight are carrying USMMA cadets). During the benchmark year, ships presently operated by those companies provided a total of 39,555 sea-days to Academy midshipmen. Therefore, MARAD divides 39,555 by the total benchmark sea-days of 47,182 to arrive at a figure of 84% restoration (rounded up from 83.8%).
In our discussions, Doherty indicated that he had not realized that sea days on ROS vessels were included in the benchmark year and acknowledged that removing them from the calculation would give a better picture of the restoration of sea year on commercial vessels. He backed out the ROS sea-days from the benchmark year and indicated that exclusion of the ROS ships cause the percentage to change from 84% to 81%.
My criticism of MARAD’s methodology
It doesn’t matter if a ship is approved by the SCCT if it is not actually taking USMMA cadets. For this reason, I disagree with MARAD’s use of their methodology for the purposes of communicating the level of restoration of sea year to the public. While it certainly made sense for MARAD to use the data to decide where to focus resources for approving companies through the SCCT approval process, the use of the same metric to inform Congress and the public about the status of the restoration of sea year does not convey a true picture of restoration. Because companies are approved but are not taking the same number of midshipmen currently as they were before the stand down, the MARAD methodology gives a false picture of the actual state of things.
Matson Shipping Company is a prime example of the issue. The information I am receiving indicates that until very recently, all of its cadet berths were taken by state school cadets. Two Academy midshipmen were recently able to join a Matson ship because their internship in a foreign shipyard was ending just as a Matson ship was leaving that shipyard. If they hadn’t been lucky to be in the right place at the right time, there’s a good chance that those berths would still be empty. I understand that there are now two other Academy midshipmen on Matson ships as well. (Matson accounted for 3,247 actual Academy midshipmen sea-days in the benchmark year.)
Liberty Maritime is another example. Although it was approved by the SCCT, it has yet to accept any Academy midshipmen, and as we announced here, it suspended its participation after it was approved. (Doherty stated that he is in touch with Liberty and advises that “cadet shipping [on Liberty Maritime] is expected to be underway shortly.” But, that was weeks ago and there still has been no change in Liberty Maritime’s status.) Yet, all of the “cadet sea days” provided by Liberty Maritime pre-stand down are being counted as restored.
A key reason that the MARAD methodology is not appropriate for measuring restoration of sea year is that it essentially assumes an instantaneous return to the way things were before the stand down. Let’s take the example of the recent approval of OSG to host Academy midshipmen during sea year. Using MARAD’s metric, the approval of OSG instantly restored 693 cadet sea-days on the date of approval; however, some of OSG’s ships were undoubtedly at sea on the date of approval and thus could not begin taking midshipmen until arriving in an appropriate port. But, an even larger problem is that other than MSP ships, the approved companies are not required to take Academy midshipmen on their vessels and, during the year of the stand down, USMMA cadet berths on those vessels have been taken by cadets from the state maritime schools. Those schools have now developed relationships with the shipping companies while USMMA’s relationship with them was destroyed MARAD’s false SA/SH narrative that defamed an entire industry and continue to place their cadets on the approved ships — to the exclusion of Academy cadets. SCCT approval does not automatically translate into cadet sea days for USMMA midshipmen.
A different way of understanding the status of the restoration of sea year is to look at the overall statistics. For the classes of 2012 through 2016, when sea year was normal, USMMA trained cadets on 360 commercial vessels operated by 67 companies. As of today, only 9 of those companies, operating only 153 ships, have been approved to participate in sea year. Only 3 additional companies, with a total of 11 ships, are pending. Companies like ExxonMobil, ConocoPhilips, Sea Bulk Tankers, Alaska Tankers, National Geographic/Linblad, Norwegian Cruise Lines, Alaska Marine Highways, KeyLakes (Great Lakes), and BG LNG Services – along with 46 other companies – no longer take Academy cadets. Clearly, the quality and opportunities offered by sea year in its current status are not close to what they were prior to the stand down.
Another major issue that must be addressed before anyone can say that sea year is truly restored – or even close to restored – is to have oil and product tankers available for sea year. For USMMA graduates who want to sail on tankers, sea year training on tankers is critical in order to get credentialed for tankers prior to graduation. Many of the tanker companies use the exposure they have to cadets on sea year as a screening tool for hiring — getting sea year experience on a tanker provides a valuable introduction to midshipmen to potential employers. At present, USMMA midshipmen have no access to the oil companies and state school cadets are getting those opportunities.
The data we need and deserve
A far better metric of the current status of restoration of sea year would be a weekly count of the number of midshipmen presently assigned to sea year along with a breakdown of the number of such midshipmen who are presently on (1) commercial ships (ideally, broken down by type of ship), (2) MSC ships, (3) state school training vessels, (4) USMMA training vessels, (5) other federal ships, and (6) ROS ships. MARAD made a start with that earlier this month when it released such data for the first week of June. But as I indicated in this post, that data reflected a brief snapshot in time when only half the normal complement of midshipmen was on sea year. On June 19, 2017, the number of midshipmen assigned to sea year increased by over 100 midshipmen (when the 2020 B-splits were assigned to sea year). Consequently, the data picture most certainly is far worse now, as I am hearing from a number of parents that their midshipmen are sitting at home awaiting a ship assignment with no news of when such an assignment might occur. Unless MARAD begins releasing weekly updates of the status of sea year assignments, the only conclusion to be drawn from its recent release of such information is that it deliberately cherry-picked the data for release at a time when the number of midshipmen assigned to sea year was half of the normal number. It is essential that MARAD release similar information on a weekly basis so that stakeholders can have an accurate picture of the progress of restoring sea year. It has that data — the recent release of information proves that. So there is no excuse for failing to publish it on a weekly basis.