THE IMPORTANCE OF EVIDENCE BASED DECISION

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1 THE IMPORTANCE OF EVIDENCE BASED DECISION MAKING: THE JONES ACT AND PUERTO RICO José J. Villamil / Eduardo Pagan (PRSA) March 7, 2014 Ponce, Puerto Rico 1

2 the problem with any ideology is that it gives the answer before you look at the evidence. So you have to mold the evidence to get the answer that you've already decided you've got to have. It doesn't work that way. Building an economy; rebuilding an economy is hard, practical nuts and bolts work. Bill Clinton 2

3 Presentation Plan The Background The Study Puerto Rico s Sinking Ship The GAO Report Global Shipping Where We Stand The Jones Act Findings Looking Forward Concluding Remarks 3

4 The Background Since the sixties the Cabotage Law has been present in policy and political discussions. Most political parties have favored its elimination. A number of studies have been completed on the subject of Jones Act implications for Puerto Rico. Up until recently none had shown material economic damages. The most recent studies done by economists Alameda and Valentín concluded that the costs were $1.3 billion in one study and subsequently lowered to $535 million. Since Jones Act carriers invoiced $710 million this figure is unlikely. The guiding principle in the study is that decisions on this subject and, in fact, all policy decisions should be evidence based, not ideology or political preferences. 4

5 The Study Commissioned by the Alianza Marítima. It was completed in early 2013 after a year of work. The study was centered on the maritime industry and its trajectory and not the Jones Act per se. Its conclusions are based on information gathered from the industry and from federal entities and international organizations. The study included an extensive literature search as well as review of most previous studies. 5

6 Puerto Rico s Sinking Ship TOTAL CONTAINER TRAFFIC HANDLED, DOMESTIC AND FOREIGN, PORT OF SAN JUAN (IN TEUS)* TRADE VOLUME AND SHARE BY COMPANY 2011 SOUTHBOUND TRADE* 2,450,000 2,300,000 2,150,000 2,000,000 1,850,000 1,700,000 1,550,000 1,400,000 1,250, Source: American Association of Ports Authorities (2012). * Includes empty containers. Company Share FEUs Crowley 31.8% 80,626 Horizon Line 29.3% 74,344 Sea Star Lines 22.6% 57,359 Trailer Bridge 16.3% 41, % 253,536 Source: PIERS data, * Northbound trade volume was 59,704 FEUs. 6

7 The GAO Report The 2013 GAO Report Key Findings and Limitations Puerto Rico still operates via a closed loop service. This has resulted in dedicated, scheduled, regular shipping services from the Jones Act carriers, which represents an important benefit to customers in Puerto Rico. Any associated cost premium relevant to the Jones Act is highly dependent upon other economic factors, many of which have a much more direct impact upon final freight rates and total transportation costs. Some services between Jones Act and foreign carriers are not comparable, and the degree of substitutability between these has not been estimated. The study also finds that the only cost advantage that foreign carriers have with respect to Jones Act Carriers is a labor-cost advantage. That cost advantage would disappear when foreign carriers would have to comply with the same labor rules and requirements as U.S.-flag container carriers. The study could not provide a rate benchmark with international freight rates, due to the refusal of participation from International liners on the study. 7

8 Global Shipping A highly concentrated market with three lines Maersk, MSC and CMA-CGM controlling 40% of the maritime cargo market. International ocean freight rates have increased substantially since 2011and rates reflect a great deal of volatility. Between 1990 and 2010, total container volume has increased by an average 8.2% annually. Total container volume has increased by over 25% since Should the Cabotage Law be repealed, Puerto Rico would be inserted in a highly concentrated market, not a competitive one. Otros 60% 40% Maersk MSC CMA CGM Otros 8

9 Where We Stand SHARE OF PUERTO RICO IN TOTAL US ATLANTIC (PLUS HOUSTON) CONTAINER PORT TRAFFIC, IN TEUS* 18.0% 17.0% 16.0% 15.0% 14.0% 13.0% 12.0% 11.0% 10.0% 9.0% 8.0% 7.0% Source: Estimated with data from the American Association of Ports Authorities (2012). * Fiscal year. Domestic and foreign trade, and includes empty containers. Data for Port of San Juan and Ponce up to Includes Tampa. 9

10 The Jones Act Adopted in It calls for ships in the domestic trade to be owned by U.S. interests, manned by U.S. crews and ships be built in the U.S. The primary reason for the cabotage clause is to assure the availability of ships in case of a military or other emergency. Initially a number of subsidies were provided but these were narrowed down to one subsidy under the Maritime Security Program. Most of the world jurisdictions have cabotage laws as well. Governor Romero, in the seventies, was able to obtain an exemption for cruise ships traveling from Puerto Rico to the U.S. Virgin Islands. Exemptions could be granted by U.S. Department of Transportation Maritime Administration(MARAD) 10

11 Findings Total billings by the four Jones Act (JA) carriers was $710 million in Overall these four carriers moved approximately 74% of total maritime cargo coming to and leaving Puerto Rico. Total southbound FEUs handled by the four carriers was 254,000 in Twenty accounts were responsible for 41% of volume. Out of the total cost of shipping a container from Jacksonville to San Juan only 16% is due to Jones Act requirements: ship depreciation and labor in the ship. Fuel, stevedoring, equipment costs (containers) and other costs are not Jones Act related. Billings JA carriers $710 million (2011) % Total maritime 74 Total FEUs 254,000 On time record 98% JA carriers have a 98% on time record, international shipping has an 80% record. This reduces costs for local importers and shippers since there is certainty concerning delivery times. The JA carriers use 40, and 53 containers. Approximately 26% of cargo comes in 53 containers which represents a major savings for importers due to economies in inland handling costs, roughly the same for 40 and 53 containers. 11

12 Findings The liner operational costs under the cabotage restriction or not, would be about the same, with the exception of vessel depreciation and vessel operations (mostly crew salaries and benefits). 12

13 Findings Estimated savings from the use of 45 /48 & 53 containers is $120 million. If only 40 containers were used 35,319 additional containers would be needed. 13

14 Findings Studies have focused on southbound trade. Rates are guessed to be higher on SB than in international shipping, but when northbound shipping is included, a weighted average of rates SB and NB is below international shipping rates by as much as 33%. Southbound accounts for approximately 80% of total maritime cargo movements into and out of San Juan. Should international shippers enter domestic trade they would be subject to federal regulations which would erase much of the advantage in costs. Comparisons between Jones Act costs and international costs have overlooked this factor. The four Jones Act carriers have invested in port infrastructure, which international lines do not. Replacement value of these investments has been estimated at $250 million. The four Jones Act carriers pays to the PR Port Authority more than $50 million per annum, in different leases and port dues. The four Jones Act employs more than 2,000 direct well remunerated jobs including millions of dollars in taxes for the Commonwealth of PR, and U.S. states. The four Jones Act pays taxes on profits to both U.S. and Puerto Rico fiscal entities. International Liners uses their flag of convenience status to pay the minimum possible. Overall capacity utilization fell from 87.7% in 2004 to 64.1% in 2011 for Jones Act carriers. 14

15 Looking Forward It is unlikely that Cabotage laws will be changed any time soon, except for amendments related to possibly LNG transports. The study presented should quiet the waters unless the data are considered to be wrong. The Port of Ponce will continue to pressure for changes, but it is faced with increased competition from others Caribbean ports, operating with significant lower labor and fringe benefit costs and less stringent customs laws. Some imports such as food, a large proportion of which comes from the mainland, could be impacted but a study on the cost of poultry in Puerto Rico reflected that Jones Act carriers could deliver poultry at a lower cost than international shippers. The global economy is moving towards production and trade in intangibles and this means that maritime cargo will not be as essential in future economic development strategies. 15

16 Concluding Remarks The Jones Act discussion is a good example of why decisionmaking based on intuition and ideological preferences could lead to wrong policies. Bill Clinton was right when he said: the problem with any ideology is that it gives the answer before you look at the evidence. So you have to mold the evidence to get the answer that you've already decided you've got to have. It doesn't work that way. Building an economy; rebuilding an economy is hard, practical nuts and bolts work. Much of what is legislated unfortunately does not comply with the requirements of fact based decision-making. Eliminating cabotage laws could very well have implications that go from greater uncertainty, the need for larger inventories to higher terminal and operational costs. Unfortunately, it is likely that Cabotage Laws will continue to be a political issue and dealt with as such. This places rational analysis in a disadvantaged position. 16

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