MARAD Seeks Information on Availability of Domestically Manufactured Ship Components

The U.S. Maritime Administration (MARAD) published its Buy America Request for Information on March 3 seeking stakeholder input on the availability of domestically manufactured ship components that can be used in construction of vessels destined for the offshore wind industry.

The Request for Information (RFI) comes as a part of MARAD’s role as administrator of the Federal Ship Financing Program (Title XI), which provides loan guarantees for construction of vessels that will be used to develop and support the offshore wind industry, among other things. Availability of domestic components is important to Title XI because the program has a domestic content requirement. While no defined amount of a vessel’s components must be domestic, MARAD excludes the costs of foreign components and services used in vessel construction from the loan amount it will guarantee unless a waiver is granted. Waivers are granted if the foreign component or service is not available in the U.S. on a timely or competitive basis or is of insufficient quality.

Currently, MARAD has flagged the following categories of ship components as “Foreign Components,” meaning those that are likely eligible for a waiver:

• • Marine Propulsion – Energy generating systems, propulsion units, transmission propulsion systems, marine diesel, support systems, fuel service and spares.
  • Navigation Systems – Interior/exterior communications, surface surveyance, navigation systems (RADAR, GMDSS, ECDIS and INMARSAT) and spares.
  • Auxiliary Systems – Pumps (including waterjet pumps and waterjet thrusters), climate control (HVAC systems), firefighting systems, compressed air systems, ventilation fans, boilers, ship control (steering, rudder, trim/heel, maneuvering, motion control/stabilizers and fins), cranes and elevators, anchoring and mooring systems.
  • Electric Plant – Electric power generation, power distribution systems (electrical switchboards and switchgear), electric motors, lighting systems, batteries (EV power generation), power generation supports, special purpose systems and spares.
  • Outfitting and Furnishing – Ship fitting, hull compartmentation (grating and ladders), motion compensation (walkway and accommodation ladders), coatings and living spaces (modular cabins).

The RFI asks stakeholders to provide information regarding components that should be added to or removed from the Foreign Components list and to describe any steps that can be taken to promote the use or development of Title XI compliant alternatives to Foreign Components where none currently exist.

MARAD hopes to use the information it gathers to better understand whether and to what extent domestic sourcing is available or may be available for commercial ship components that have historically come from foreign sources. With that information in hand, MARAD intends to assist U.S. shipbuilders and operators in identifying component markets that comply with Title XI’s domestic content requirement.  

Given the information requested and the waiver requirements imposed by Title XI, a robust response to the RFI has the potential to impact component manufacturers and shipbuilders in meaningful ways.

Domestic component manufacturers and service providers will be able to leverage the RFI to get their name in front of the growing offshore wind industry. If done right, simply responding to the RFI could be a boon to business for companies providing alternatives to Foreign Components or planning to do so in the future. As a result of better information on domestic availability, the shipbuilders and operators requesting MARAD loan guarantees will be less likely to get foreign component waivers. When waivers are more difficult to get, loan recipients will have to decide if it makes more sense to use domestic components and secure a fully guaranteed Title XI loan or use foreign components and have that cost subtracted from the guarantee.

Because of the nature of MARAD’s request, both component manufacturers and shipbuilders will benefit from providing comments to the RFI. Domestic manufacturers can assert themselves into the market while shipbuilders can provide data justifying the use of Foreign Components with an eye toward keeping waivers available.  

If you are a domestic shipbuilder, component manufacturer, or service provider, getting your comments into MARAD is important. If you have questions about this RFI or other marine aspects of the U.S. offshore wind industry, contact Evan Spencer or any member of Phelps’ Admiralty team.