Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40APRIL 2017 • FOGHORN 27 REGULATORYREPORT Navigating your risks, day and night. As the owner of a passenger vessel you face tough decisions every day, from hiring qualified crew to making sure your vessel is in prime condition. At Aon, we spend day and night thinking about your maritime risks so buying insurance doesn’t have to be another tough decision. We work with you to develop creative approaches and customized solutions that deliver more efficiencies, improved profitability and greater value. For more information, please call 1.800.730.7053 or visit passengervessel.com/member-resources.html#insurance Risk. Reinsurance. Human Resources. Navigating your Aon Risk Solutions Marine require immediate notification to the Coast Guard. This immediate notifi- cation enables Coast Guard personnel and resources to respond to threats to life, property and navigation as well as facilitating immediate investigation when appropriate. It is here that re- portable casualty introduces a specific property damage level as a reportable incident that also covers those casualty or accidents defined in 46 CFR 4.03-1. The dollar threshold in marine casualty reporting and SMI reporting is a number that, if properly set, estab- lishes a level of property damage that is complementary to the other defined accidents and incidents. It is an “all other” type definition that captures po- tentially significant events that are not otherwise already identified marine accidents or incidents that are readily understood events in the ordinary discourse of business. The method the Coast Guard picked to adjust their numbers would seem logical on its surface, but suffers from any degree of scrutiny. Let us start with first and most obvious question: what is the consumer price index for all urban consumers or the CPI-U? The major CPI-U items tracked are: food at home, food away from home, energy com- modities, energy services, commodi- ties less food and energy commodities, service less energy services, medical care services, and transportation services. The sub–items represented by these categories make it even more puzzling in their relationship to what we in the marine industry consider routine repair and replacement of vessels, equipment and accouterments. We have to do better. We can! The Bureau of Labor Statistics (BLS) maintains many other information compilations and we will discuss three here that are part of our comments to the docket. The BLS Current Employment Statistics – CES National is an analysis of straight-time, average hourly earnings for steel vessel construction. It has a base year of 1982 and shows a value of 322.6 for December 2016. The BLS Labor Index of Straight-Time Average Hourly Earnings – All regions with a base year of 1987 shows a value of 242.2 for November 2016. In the casualty repair, labor is the most significant cost. Removal of damaged material, relocation of imped- iments and services in way of access, gas freeing, surface and joint prepara- tion, off site repair of components, dis- assembly and reassembly, and all the other labor intensive acuities that are associated with a physical restoration can run to 80 or 90 percent of the total repair costs. The BLS Material Index for Steel Vessel Contracts with a base year of 1982 shows a value for January 2017 of 200.4. In a Rand study done for the Navy, “Using the Steel-Vessel Material –Cost Index to Mitigate Ship Builder Risk has some interesting observations in