Costs of Marine Engineering and Naval Architecture Services. Douglas Scheffler, Brandon Lee, and Jeffrey V. Conopask, Ph.D. 1

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1 Costs of Marine Engineering and Naval Architecture Services by Douglas Scheffler, Brandon Lee, and Jeffrey V. Conopask, Ph.D. 1 Abstract The U.S. Coast Guard in consultation with ABS Consulting, conducted a study on the costs of marine engineering and naval architecture services and related industry practices in The goal for this study was to provide information on industry costs and practices to support the Coast Guard s regulatory development program. The findings of this study provide information on the costs and the reasons for the variability of the costs for a suite of vessel inspection activities. The information compiled by this study indicates that there is not a general market for marine engineering and naval architecture services in the United States. Instead, the costs of each service are driven by the characteristics of the service and the vessels receiving the service. Introduction The U.S. Coast Guard (USCG) is the Federal government s lead regulatory agency with respect to maritime matters, including navigation, marine safety, and protection of the marine environment. 2 When it issues regulations in support of these missions, the USCG must follow multiple statutory and policy requirements, including Executive Orders and and provide regulatory analyses that show that the costs of proposed rules are justified by their expected benefits. This report describes the results of analyses in support of a USCG-sponsored study of Marine Engineering and Naval Architecture Costs for Use in Regulatory Analyses. 5 The goal of this study was to systematically collect information on the costs of marine engineering and naval architecture services. The immediate application of the data is to support the USCG s regulatory development program by filling knowledge gaps related to maritime engineering and architecture services and provide a baseline of cost data for 1 Mr. Scheffler and Dr. Conopask are economists with the USCG s Standards Evaluation and Analysis Division, Mr. Lee is a program officer with ABS Consulting Contract GS-23F-0207L for the Coast Guard Standards Evaluation and Analysis Division (CG-REG-1) as performed by American Bureau of Shipping Group Consulting (ABS Consulting)

2 specific services. We anticipate that this information also will be useful to the broader U.S. maritime community. As part of this study, we conducted a survey of existing literature on costs of marine engineering and naval architecture services. We reviewed information from a variety of sources, including Web sites, publications, financial filings with the Securities and Exchange Commission (SEC), data clearinghouses, and industry journals (Maritime Professional 6, Maritime Reporter and Engineering News 7, Marine News 8, MarineLog 9, and WorkBoat 10 ). We identified external databases (IHS Fairplay database 11, U.S. Army Corps of Engineers Navigation Data Center s Waterway Data 12, Greenwood s Guide 13 ) but we did not utilize them for this report due to financial constraints or limited usability. Our literature review uncovered numerous large data gaps. Financial filings did not provide adequate detail about costs for marine engineering and naval architecture services. Publications contained cost information for individual vessels, which may not be representative of the vessel type. Additionally, not all vessel types were discussed in the publications. The most common vessel types discussed were towing boats, offshore supply vessels, and ferries, whereas the USCG s regulatory scope also includes larger commercial and passenger vessels. The remaining sections of this paper are: data collection, the data analysis, findings, future research, and a conclusion. Data Collection The data we collected included information on the costs of marine engineering and naval architecture services and related industry practices. The specific services covered in this report are the following: Vessel Inspections; Vessel Examinations; Vessel Classifications; Vessel Surveys; Drydocking; Greenwood s Guide to Great Lakes Shipping, Harbor House Publishers, Boyne, MI,

3 Alternative to Drydocking; Ballast Water Tank Inspection; Ballast Water Tank Cleaning; and Vessel Modifications. We developed a taxonomy for the purpose of this report based on Code of Federal Regulations (CFR) regulatory areas 14 and refined by the USCG user-fee schedule 15. Table 1 displays the vessels as identified by type and their divisions by either length or gross tonnage. Table 1: Vessel Taxonomy Inspection User Fee Schedule Vessel Type Divisions Freight Barges Length 300 Freight Barges Length > 300 Freight Ships Length 300 Freight Ships Length > 300 Industrial Vessels Length 200 Industrial Vessels Length > 200 Mobile Offshore Drilling Units (MODUs) Nautical School Vessels Oceanographic Research Vessels Offshore Supply Vessels Passenger Barges Gross tons < 100 and: Length < 65 Passenger Barges Length 65 Gross tons 100 and: 14 General requirements. 46 CFR vol1/cfr-2008-title46-vol1-sec /content-detail.html. 15 Annual vessel inspection fee. 46 CFR title46-vol1/cfr-2001-title46-vol1-sec /content-detail.html.

4 Vessel Type Divisions Certified for fewer than 150 passengers Certified for 150 or more passengers Passenger Ships Length 250 : Certified for fewer than 150 passengers Certified for 150 or more passengers Passenger Ships Length > 250 and 350 Passenger Ships Length > 350 and 450 Passenger Ships Length > 450 Sailing School Vessels Small Passenger Vessels Length < 65 Small Passenger Vessels Length 65 Tank Barges Tankships Length 300 Tankships Length > 300 Liquefied Gas Tankships Sea-going and Other Towing Vessels under USCG s Regulatory Scheme The taxonomy served as the basis for the compilation of the services costs. We did not include commercial fishing, towing, and recreational vessels as vessel types, as these vessel types are not subject to the same regulations as other vessel types and are covered under Subchapter C: Uninspected Vessels. Recreational and commercial fishing vessels tend to be categorized in sizes smaller than other vessel types. Because of the smaller size of these vessels, they rarely interact with commercial shipyards. Consequently, we found it difficult to obtain pertinent information for these vessel types We also found that for some services, there was not much variability across vessel type. ABS Consulting conducted an internal data search by interviewing employees of the ABS organization. Individuals interviewed included vessel inspectors and surveyors. These

5 employees provided inspection and survey cost data for all types of classed 16 and unclassed vessels. In order to focus this study within the confines of limited fiscal resources, this study focused on the Gulf Coast region of the USCG s Eighth District and the Hampton Roads region of the USCG s Fifth District. (Insert Figure 1, CG District map) ABS Consulting conducted interviews with industry representatives to identify costs and to determine the drivers of these variations at major port areas within the two selected regions. These industry representatives provided background information on the various services and estimations of the related costs for their respective regions. The data gathered in the regional interviews were cross-referenced with the data collected from internal ABS Consulting sources and the literature review. ABS Consulting utilized three other main sources to determine specific costs: 1) a database previously created by ABS Consulting to determine costs for hull cleaning; 2) the ABS Fee Schedule to determine costs for surveying; and 3) Don Butler s A Guide to Ship Repair Estimates (in Man Hours), 2nd edition 17 to create baselines for ship repair costs from practical estimations. Data Analysis Study profile In general, vessel type and length are the primary specifications used by vendors to develop costs for each service. Many of the vessel types have a break point between a small vessel and a large vessel at around 300 feet in length. In cases where the shipyard or the classification society did not break costs down by length, tonnage was utilized instead. Our research indicates that a similar break point for tonnage is at 3,000 gross tons. To create a national profile of costs, data from two regions were averaged. Data are provided based on the regional source. The values could be: Obtained from the Gulf Coast region only; Obtained from the Hampton Roads region only; An average between the averages of the Gulf Coast and the Hampton Roads regions; 16 For information on classification of vessels and classification societies, see ABS web site: gelabel=abs_eagle_portal_classification_book. 17 Butler, Don, A Guide to Ship Repair Estimates (in Man Hours), 2 nd ed., Waltham, MA, Elsevier Science, 2012.

6 The average of the maximum from one region and the minimum from another region; or The same, regardless of region. Findings In this section we present the major findings of the study. They include general topics of hourly labor rate; vessel length as a cost driver; and costs of specific services. Hourly Labor Rate In general, the wages charged to the client would include those for general labor, docking, and other specialized activities like welding or working sheet metal. Overhead costs like administration and management are included in the man-hour calculations. Activities like welding or working sheet metal require more time than other activities, but the hourly rate is held static for most of these tasks at the shipyards we visited. Rates for specialized labor for specific tasks involving activities such as environmental compliance, ballast water operations, and marine chemistry, were cost out on a projectby-project basis. The shipyards we interviewed outsourced these services; thus, the costs are not specified for a type of work. A major finding of the study was that the hourly rate charged for a labor-hour is dependent on the market. In the Gulf Coast region, the market rates were very competitive, as indicated by little fluctuation in the rate charged across firms. The hourly rates of the drydocks we interviewed in the Gulf Coast region were close to $55 on average, with the highest rate of approximately $56 and a minimum rate of $48. Based on data from the studies, interviews, and internet searches, we concluded that the typical hourly rate in shipyards across the nation is approximately $75 per hour, with rates ranging as high as $85 per hour. Premium rates for overtime and subcontractors were higher. Overtime work was often billed at $96 per hour, with an additional 125 percent retail cost for subcontractors. (Subcontractors are often used for specialized tasks such as ballast water tank cleaning and water removal.) The Gulf Coast region had the lowest rate charged for a labor-hour of the regions interviewed. Surveying activities conducted by ABS Group Quality Evaluations charge $150 per hour. For classification activities, ABS Group Quality Evaluations may charge as much as $160 per hour. For the academic and industry sources we reviewed that used labor hours instead of a market rate, a national average for the labor-hour rate was applied. For this study, we used the consensus national shipyard rate of $75 per hour as a representative wage rate. Vessel Length

7 For many services, vessel length and not vessel type was used to determine cost. Inspections are the only service whose costs are based on vessel type in addition to length. Certain vessel types have their own cost structure. Oceanographic research vessels, lighter aboard ship (LASH) carriers, and mobile offshore drilling units (MODUs) have different naval architecture configurations and, therefore, are often charged differently than other vessels. Inspections There are three types of vessel inspections: inspections for certification, annual inspections, and periodic inspections. Each inspection occurs at least once every five years and includes inspecting the navigation systems, cargo systems, life-saving systems, and fire-fighting systems, and reviewing crew drills and pollution prevention procedures. The inspection for certification is the most rigorous inspection, occurring once every five years. Periodic inspections are less rigorous than the inspection for certification. They are conducted twice within the five-year period of an inspection for certification. Annual inspections are the least rigorous inspections, occurring every year the vessel is not required to have a periodic inspection or inspection for the purpose of certification. Inspection costs vary depending on the type of inspection, the size of the vessel, and the time it takes to conduct the inspection. The USCG is responsible for inspections and the issuance of Certificates of Inspection, for which services it charges a fee. 18 Alternately, classification societies can conduct inspections on behalf of the USCG through the Alternative Compliance Program 19, usually at a cost to the owner. The inspection fees do not reflect the additional cost to drydock each vessel. Inspection fees are categorized by vessel type and size. The time required to inspect a vessel is typically proportional to the its length. Smaller vessels are assumed to take on average of three days to inspect: one day to drydock and prepare the vessel for inspection, one day for inspection, and one day to launch. Larger vessels may require a longer inspection time, often on a one to two week time-scale. Table 2 presents our findings on the costs of inspections. Table 2: Annual Vessel Inspection Costs Annual Vessel Inspection Fee CFR , chapi-subchapa.pdf, p

8 Annual Vessel Inspection Fee Vessel Type Vessel Size Minimum Average Maximum Freight Barges 300' $495 $553 $610 >300' $955 $955 $955 Freight Ships 300' $1,425 $1,648 $1,870 >300' $5,410 $5,410 $5,410 Industrial Vessels 200' $1,435 $1,435 $1,435 >200' $2,550 $2,550 $2,550 Mobile Offshore Drilling Units (MODU) Nautical School Vessels Oceanographic Research Vessels Offshore Supply Vessels $4,695 $6,373 $8,050 $835 $4,020 $7,205 $840 $2,225 $3,610 $1,135 $1,303 $1,470 Passenger Barges <100 GT and <65' $300 $300 $300 65' $600 $600 $ GT and <150 passengers $2,215 $2,215 $2, passengers $2,525 $2,525 $2,525 Passenger Ships 250' and <150 passengers $3,600 $3,600 $3, passengers $4,050 $4,050 $4,050

9 Annual Vessel Inspection Fee >250' and 350' $5,330 $5,330 $5,330 >350' and 450' $6,835 $6,835 $6,835 >450' $14,650 $14,650 $14,650 Sailing School Vessels Small Passenger Vessels $530 $755 $980 <65' $300 $300 $300 65' $600 $600 $600 Tank Barges >100' $500 $500 $500 Tankships 300' $1,295 $1,803 $2,310 >300' $5,805 $5,805 $5,805 Liquefied Gas Tankships Sea-going and other Towing Vessels under USCG s regulatory scheme $12,120 $12,120 $12,120 $1,030 $1,030 $1,030 Examinations There are three types of examinations: a drydock examination, an internal structural examination, and a cargo tank internal examination. Vessels are required to undergo two examinations per examination type every five years. We did not find significant variation in costs across the study s vessel taxonomy. The typical range for vessel examination costs was between $3,500 and $15,000. Classifications There is no regulatory vessel requirement to be classed. However; there may be industry requirements for classification to conduct certain operations (particularly for the oil and gas industry).

10 Since the classification standards of ABS are more stringent than the requirements for vessel inspection by the USCG, classed vessels are allowed to use their classification inspections instead of a USCG inspection. The USCG can choose to delegate inspection functions to approved organizations, such as ABS, under the Alternate Compliance Program. This delegation reduces the number of inspections necessary to just the classification inspection instead of both the classification inspection and the USCG inspection. Since vessel classification is not required, it represents an additional cost incurred by the vessel owner. However, many vessel owners who choose not to have a vessel classed still build their vessels to meet class standards. Classification costs are set by ABS at the port; however, there were no regional differences within the United States. Vessel classifications for relatively small vessels cost between $6,000 and $10,000. Surveys A survey is not a requirement for unclassed vessels. It can refer to an investigation into a specific area of the vessel or a general check of the entire vessel. A survey can be conducted to determine the overall condition of a vessel; however, often a survey is done for a specific system. Surveys are usually conducted by a surveying company like ABS and its affiliated companies for unclassed and classed vessels, but can be done by classification societies or even by the shipyard. Cost and frequency of vessel surveys and inspections vary based on the type of survey, whether the vessel is classed or unclassed, the size of the vessel, and the time it takes to conduct theinspection. Due to broad variances in the types of surveys and the vessel sizes, little data were available for vessels greater than than 300 feet in length. For vessels less than 300 feet in length, the costs of a survey range from $750 to $1,500. Drydocking Vessels drydock for two main reasons: regulatory requirement and emergency repairs. Vessel owners typically wait until the mandatory drydocking period to complete any nonemergency repairs, modifications, or maintenance. Drydocking occurs more frequently under certain circumstances, such as advanced vessel age (which may require more out-of-water inspections) and in the event of emergencies that raise concern over hull integrity (e.g., significant scraping or bumping of a vessel hull).

11 How long a vessel remains in drydock depends on the type of work being done on the vessel. For smaller vessels, the drydocking period may be as short as a single day, whereas larger vessels may need longer drydocking periods. Drydocking costs vary based on vessel size, vessel weight, equipment, type of work, and the type of drydock needed to accommodate the particular vessel. Most shipyards have inclusive rates, often charging a flat rate either by day or by estimated costs for the contracted drydocking period. These costs ranged from $2,000 to $250,000. The largest passenger ships can have higher costs of up to $1,000,000. The overall costs covered the labor costs for setting up the blocks and operating the switchboard required during drydocking, but could also include additional costs for services involving power, docking, potable water, and waste processing. These services, combined with berth preparation, docking, and undocking, compose the typical baseline drydocking estimates. Table 3 presents data on drydocking following our vessel taxonomy, with additional data on drydocking frequency and duration. Table 3: Annual Drydocking Costs, Durations, and Frequencies Drydocking Frequency (Years) Drydocking Duration (Days on the dock) Drydocking Cost Vessel Type Vessel Size Highest Ave Lowest Min Ave Max Min Ave Max Freight Barges $2,000 $11,750 $50,000 > $5,000 $25,000 $50,000 Freight Ships $2,000 $9,250 $20,000 > $10,000 $25,000 $50,000 Industrial Vessels $2,000 $9,250 $20,000 > $8,000 $15,000 $50,000 Mobile Offshore Drilling Units (MODU) Nautical School Vessels Oceanographic Research Vessels $50,000 $100,000 $250, $5,000 $15,000 $25, $2,000 $11,750 $25,000

12 Offshore Supply Vessels $2,000 $11,750 $25,000 Passenger Barges <100 GT and $2,000 $8,500 $15,000 < GT and $25,000 $50,000 $100,000 <150 passengers $25,000 $50,000 $100, passengers $30,000 $75,000 $150,000 Passenger Ships $2,000 $8,500 $15,000 <150 passengers $5,000 $25,000 $50, passengers $15,000 $30,000 $100,000 >250 and 350 >350 and $60,000 $150,000 $600, $5,000 $200,000 $800,000 > $100,000 $300,000 $1,000,000 Sailing School Vessels $1,200 Small Passenger Vessels < $2,000 $5,000 $25, $5,000 $6,000 $10,000 Tank Barges > $2,000 $14,250 $50,000 Tankships $2,000 $14,250 $40,000 > $5,000 $75,000 $100,000 Liquefied Gas Tankers $100,000 $150,000 $200,000 Sea-going and other Towing Vessels under USCG s regulatory scheme $2,000 $16,750 $100,000 Alternative to Drydocking The only alternative to drydocking identified was underwater surveys, in which divers survey and repair a vessel underwater. Most shipyards do not have a diver on staff;

13 rather, if underwater inspection is requested or required, the diver is commonly hired by the vessel owner or subcontracted by the shipyard. Very large vessels in congested ports may opt for this to save time. ABS does not charge an additional rate for an underwater survey versus a regular survey. The 2011 ABS Fee Schedule indicated that the base fee for underwater inspections for all vessel types is between $477 for smaller vessels, and up to $1,531 for larger vessels, which was the same range given by the 2011 ABS Fee Schedule for annual and intermediate hull survey costs. Ballast Water Tank Inspection and Cleaning Unlike many of the naval architecture and marine engineering service costs, costs for inspecting ballast water tanks are determined mainly by the number of ballast water tanks on board the vessel rather than the type and size of the vessel. Therefore, any estimation of costs for ballast water tank inspection and cleaning are vessel-specific. Surveys and inspections normally include an examination of just one or two representative ballast tanks rather than every tank on the vessel. In addition to vessel-specific costs, estimates for inspecting a ballast tank vary from shipyard to shipyard, even in the same region. Most shipyards interviewed did not perform ballast tank cleaning, but subcontracted the work out to another vendor. According to the 2011 ABS Fee Schedule, the cost of ballast water tank inspections for each tank was $480 per hour, and is charged for the initial, annual, intermediate, and renewal ballast water tank surveys. Ballast water cleaning rates ranged from $1,000 to $20,000 per tank depending on the shipyard and the tank size. Industry representatives estimated that the cost range for ballast water tank cleaning services was $6,500 to $10,000 for small vessels. Vessel Modifications Vessel modifications cover a broad variety of naval architecture and marine engineering services. These costs depend on the type of work being done. Vessel modifications like a new coat of paint take less time than installing a new engine or new ballast water treatment equipment. Propulsion and steering systems modifications may require extensive removal of ship components, increasing the time necessary to complete the modifications. Depending on the extent or complexity of the modification, the modification period may take anywhere from days or weeks to months or, potentially, years. The more extensive modifications like those made to propulsion or steering systems can take as many as one to five years to complete for certain vessel types.

14 Future Research This study identified six additional areas for further research: 1) vessel taxonomy; 2) additional factors of cost; 3) additional vessel types; 4) vessel age; 5) additional regions; and 6) additional classification societies. See the discussion below of each area Vessel Taxonomy Since we found that many costs were determined by vessel length rather than vessel type, we recommend creating a taxonomy that utilizes length as the primary key, with vessel types secondary. In addition, we believe that identifying a rough relationship between vessel length (and the related vessel types) with vessel gross tonnage would be beneficial. Additional Factors of Cost Several cost data categories could be included in future studies to help account for regional disparities. The cost of education, the cost of living, and the competitiveness of the market are major factors in shaping regional and local naval architecture and marine engineering fees. Future studies could identify hourly labor rates of regional drydock operations as well as identify regional business activity as a whole. In addition, the actual costs to vessel owners could also be clarified and examined since the cost data compiled in this report generally was not obtained through interviews with vessel owners. Additional Vessel Types We discovered that cost data was difficult to populate for four vessel types: commercial fishing, towing, MODU, and recreational. We recommend a focus on these vessels, which would require a different approach and data collection method than the vessel types captured in this study. Vessel Age We found that determining costs by vessel age to be difficult during the course of this study. We believe that vessel age is a determining factor in the costs related to marine engineering and naval architecture, but we were not able to obtain adequate information to verify the validity of this hypothesis. Additional Regions We interviewed only industry representatives in two of the nine USCG Districts. We recommend examining the regions omitted in this report, namely the Great Lakes, Pacific Northwest, West Coast, South East, and New England regions.

15 Additional Classification Societies This study obtained fee data from only one classification society. A follow-up study should attempt to obtain data from other classification societies, while protecting proprietary information. Conclusion The information compiled by this study indicates that there is not a general market for marine engineering and naval architecture services in the United States. Instead, the costs of each service are driven by the characteristics of the service and the vessels receiving the service. The major specific findings of this study are: Hourly wage rates are dependent on regional markets. The Gulf Coast region has a competitive labor market with rates ranging between $48 and $56 per hour. The national average is approximately $75 per hour, with a high of $85 per hour. There is no uniformity concerning the range of costs of the services studied. Some services have limited ranges classifications costs range from $6,000 to $10,000, and underwater surveys range from $477 to $1,531. Conversely, inspections, examinations, and drydockings have much wider ranges. Inspections vary from $495 to $14,650; examinations from $3,500 to $13,500; and drydockings from $2,000 and $1,000,000, with the largest vessels ranging from $250,000 to $1,000,000. In general, vessel type and length are the major drivers of costs of services. However, some specific services may have different cost drivers. For example, the costs of ballast tank inspections and cleaning services depend on the number of tanks; the costs for drydocking services depend largely on the duration of time a vessel spends in drydock.

16 Figure 1, U.S. Coast Guard Districts