MAY 2018 • FOGHORN 25 REGULATORYREPORT maritime industry, but we wish to bring to the Coast Guard’s attention several indices of the U.S. Bureau of Labor Statistics that estimate cost escalation in sections of the marine building and repair endeavor. 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” shows a value of 242.2 for November 2016. It has a base year of 1987. Incidentally, naval architects advise PVA that labor costs constitute 40-50 percent of new vessel construc- tion, while they make up a whopping 80-90 percent of vessel 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. However, a Rand study done for the Navy entitled “Using the Steel-Vessel Material — Cost Index to Mitigate Ship Builder Risk” cautions that this particular index assumes a proportion of steel than is generally typically the case in the construction of a modern ship and therefore does not accurately cover the cost of material used in building a modern vessel, par- ticularly one that uses aluminum, as is common for many new ferries and passenger vessels. The degree to which these ship- building-related indices may be ap- plicable to the U.S. passenger vessel industry can be debated, but collective- ly their credibility for purposes of this rulemaking is far superior to the Coast Guard’s choice of CPI-U.” Nonetheless, we are pleased that the final rule raised the damage thresh- olds and while we believe that a higher threshold could be justified, the Coast Guard will review these numbers in five years. When that happens, please rest assured that we will strongly advocate for the use of the afore- mentioned Bureau of Labor Statistics indexes to calculate future increases in damage thresholds. n Kitchen Public Relations, LLC Mr. David Norman New York, NY Associate www.kitchenpr.com PVA WELCOMES NEW MEMBERS Buffalo Sailing Adventures Capt. Rich Hilliman Buffalo, NY Vessel www.spiritofbuffalo.com Sea School Mr. Ken Wahl St. Petersburg, FL Vessel www.seaschoolonline.com