How MARAD is calculating the restoration of sea year

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.

MARAD’s methodology

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.

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11 Comments

  1. I believe that Sea Year should be fully restored and that US Flag merchant ship companies should be encouraged to take KP cadets on board, in spite of any new burdens put upon them. Hopefully the new Marad Administrator will work to that end. In addition, the recent cancellation of traditional Sea Year training has perhaps presented new opportunities….especially by sailing on US Navy vessels. Our Mids. have gotten stellar reviews while serving on Navy ships. If that time counts towards attaining their license and encourages active duty as well as service on merchant vessels, that sounds good.

  2. I am a cadet currently on a Matson ship. The other cadet is a state schooler. Hopefully, Matson will open their fleet back up to KP when all of the cal maritime kids get off. But I must say that for being the first KP cadet in this ship since the standing I have gotten no snide remarks about the stand down or anyone shying away from teaching me. It seems like business as usual and I am being treated as a normal crew member. I know that this isn’t what the post was about but I haven’t seen any first hand accounts on if cadets are being treated differently. And at least on my ship they aren’t.

  3. “Figures do not lie, but liars do figure.” –
    Author Unknown (commonly misattributed to Twain)

    Someone should make a chronological list, since Summer of 2012, of all lies by MARAD and Helis.

    Unfortunately, as Stakeholders, we have gotten to the point where we can no longer believe anything Acting MARAD Szabat and Colonel Helis say.

    #DrainMARAD
    #DrainWileyHall

  4. Hi Andy,

    Glad to see you continuing this effort, even over the holiday.

    There is one other detail to consider regarding the tanker companies lack of participation. Not only do the mids miss the corporate exposure that you note, but they are also unable to get the time needed for PIC eligibility. In today’s job market this pretty severely restricts job opportunities, for deckies at least. I believe it takes 90 days aboard a tanker for this. Getting this after you get your license is pretty hard if not a practical impossibility, unless someone has a solution for it that I am unaware of.

    Thanks,

    Erik

    • Eric. The problem here is a guy named brian blower. He says he is a KP grad. His response when I pressed him about this was it was “normal” for KP 3rd mate graduates to work for a year as an AB on a tanker to be able to “qualify” as a 3rd mate.

      I told him I sailed right away as a tanker mate. He was unwilling to accept that recent grads could get jobs on tankers.

      Not comforting. But you are correct about the PIc qualification. Soon the tanker mate supply will run out and that will be a different disaster.

      • I sailed as a 3rd mate on a chemical tanker shortly after graduation — without sailing as an AB or in any other capacity on a tanker post-graduation. I had four months as a cadet on a Keystone crude tanker running between Valdez and San Francisco and it was an incredibly valuable experience and I was well-prepared to step aboard the tanker as a 3rd mate.

  5. Some suggestions for Admiral Buzby: call in all the companies that previously took Cadets and find out exactly why they have stopped; expedite the approval process; confirm with the USCG as to what exactly is required for the sea time requirements. Of course this will require the hiring of KP assistants in order to get the job accomplished.

  6. First look at the bright side- at least Mr.Doherty at MARAD was good enough to provide KPS with legitimate material to work with, even if we do not agree with the methodology. It seems to be a big improvement over the secrecy of the last 12 months that we got fron Janechin, Rodriguez and Helis.
    Also, at least things are moving in the right direction, even if it’s at a snail’s pace. Thank you, Mr Doherty.

    On the negative side, the facts, as we finally have them, make clear that a full restoration of sea year is far more than 16% away, as touted by Helis. We have to keep up the pressure. At least 2 classes at the Academy (19 and 20) have been short changed in their promised education in an attempt to distract from administrative and leadership failures.

    What a shame.

  7. My son, USMMA ’16, sailed as a tanker mate without sailing unlicensed. Crowley tankers already have 2017 mates and engineers sailing as licensed mates and engineers – a few weeks after graduation. Mr Blower needs to get out of DC and see the real world!

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