California Naval Architect & Marine Engineer Bus. & Prof. Code § 6701 Attorney Fee Petition Mechanics: PE-NNNNN License Verification at search.dca.ca.gov as Primary Welch Anchor (THE ONLY § 6701 Naval Architect & Marine Engineer Page — DISTINCT FROM Mechanical Engineer PE-ME, Civil Engineer § 6730 PE-CE, Structural Engineer § 6736 SE, and Petroleum Engineer PE-PE; ABS Rules for Building and Classing Steel Vessels (2024) Advisory [PURE KETCHUM]; SNAME Technical Bulletin 3-60 Ship Structural Design Advisory [PURE KETCHUM]; TWO PRIVATE STANDARDS ON ONE PAGE), CCP § 1021.5 Private Attorney General Mandatory Attorney Fees

Statutory Framework: Bus. & Prof. Code § 6701 and PE-NA Licensure — Naval Architect Requirements, Scope of Practice, ABS Rules for Steel Vessels [PURE KETCHUM], SNAME Technical Bulletin 3-60 [PURE KETCHUM], and CCP § 1021.5 Mandatory Attorney Fees

California Business and Professions Code § 6701 defines naval architecture and marine engineering as a branch of professional engineering encompassing vessel design, hull form development, vessel stability analysis and booklet preparation, hull structural design and analysis, marine propulsion and machinery system engineering, mooring system design, vessel resistance and powering calculations, seakeeping analysis, and preparation of engineering documents for vessel classification, USCG certification, and California State Lands Commission marine terminal regulatory compliance. § 6701 requires that naval architecture and marine engineering documents — including vessel stability letters and stability booklets, hull structural calculations, mooring system engineering reports, and vessel modification engineering drawings submitted to the USCG, ABS, or California State Lands Commission — be prepared and stamped by a PE-NA licensed by BPELSG. § 6785 prohibits unlicensed engineering practice; a person who prepares and stamps naval architecture engineering documents without a valid PE-NA commits § 6785 unauthorized engineering practice, actionable under CCP § 1021.5 when the litigation vindicates a public interest in maritime passenger safety and port infrastructure protection. Primary Welch anchor: BPELSG License Verification at search.dca.ca.gov (PE-NNNNN module, PE-NA designation).

ABS RULES FOR BUILDING AND CLASSING STEEL VESSELS (2024) ADVISORY — THE ONLY PAGE IN THE FEE-PETITION-MECHANICS SERIES WITH AN ABS RULES FOR BUILDING AND CLASSING STEEL VESSELS ADVISORY — PURE KETCHUM: The American Bureau of Shipping (ABS, founded 1862, Spring TX) is a private nonprofit international maritime classification society. ABS Rules for Building and Classing Steel Vessels (2024) establish the classification requirements for steel vessels and are widely referenced for naval architecture practice. Key ABS Rules requirements applicable to naval architecture engineering practice include: (1) Part 3 Chapter 2 Section 2 — hull girder section modulus requirements for longitudinal strength, including minimum section modulus calculation for the midship cross-section considering effective breadth of plating, structural continuity at hatch openings, and corrosion addition for service life; (2) Part 3 Chapter 5 — intact stability criteria for all vessel types, including minimum metacentric height (GM) requirements by vessel type (GM ≥ 0.60 m for passenger vessels), GZ righting lever curve area criteria (minimum positive GZ area to 30° and to minimum 60°), downflooding angle requirements, and stability booklet content and approval requirements; (3) Part 7 Chapter 1 — mooring system design load calculation methodology for vessel at berth, including environmental load combinations (wind load + current load + wave load from the governing direction), mooring line breaking load selection, and fender system reaction load determination. A naval architect who calculates passenger vessel GM at 0.42 m — below the ABS minimum 0.60 m — without identifying the stability deficiency and issuing a stability letter certifying adequate stability commits a documented ABS Part 3 Chapter 5 practice deficiency. ABS Rules create no statutory fee-shifting; they are PURE KETCHUM advisories.

SNAME TECHNICAL BULLETIN 3-60 SHIP STRUCTURAL DESIGN ADVISORY — THE ONLY PAGE IN THE FEE-PETITION-MECHANICS SERIES WITH A SNAME TECHNICAL BULLETIN 3-60 ADVISORY — PURE KETCHUM: The Society of Naval Architects and Marine Engineers (SNAME, founded 1893, Jersey City NJ) is the preeminent private nonprofit professional organization for naval architects and marine engineers. SNAME Technical Bulletin 3-60 (Ship Structural Design) provides guidance for ship structural engineering practice. Key SNAME Bulletin 3-60 requirements applicable to naval architecture engineering practice include: (1) Section 4.2 — spectral fatigue life assessment methodology for ship structural details, including sea state scatter diagram selection, stress transfer function calculation, cumulative damage ratio (Miner’s rule) computation, and minimum fatigue life criteria for critical structural connections including hatch corner brackets, deck-side shell connections, and superstructure corners; (2) Section 5.1 — structural modeling requirements for finite element analysis of critical hull structural connections, including mesh density criteria, boundary condition specification, load application methodology, and acceptance criteria for calculated stress concentrations at weld toes and plate intersections; (3) Section 6.3 — criteria for weld joint classification (B, C, D, E, F, F2, G, W) and permissible stress range (S-N curve selection) for welded joints in ship structural steel under cyclic loading, including surface finish and geometric stress concentration adjustments. A naval architect who stamps a vessel structural design for a 65-foot sailing yacht without performing SNAME Bulletin 3-60 FEA for the mast base deck/cabin structural intersection — where mast compression loads create concentrated in-plane and out-of-plane deck loads — commits a documented SNAME Bulletin 3-60 structural engineering deficiency. SNAME Bulletin 3-60 creates no statutory fee-shifting; it is a PURE KETCHUM advisory.

Three-Track Harm: SF Bay Ferry ABS GM Deficiency USCG Out-of-Service ($285K), Port of Long Beach Mooring Load Combination Omitted Storm Line Parting ($195K), and Sailing Yacht SNAME FEA Mast Base Deficiency CSL Patrol Order ($95K)

• UNLICENSED NAVAL ARCHITECT PERFORMS FERRY VESSEL STABILITY ANALYSIS FOR SAN FRANCISCO BAY PASSENGER FERRY WITHOUT PE-NA LICENSE (BPELSG CONFIRMS NO PE-NNNNN PE-NA IN DATABASE) — ABS RULES PART 3 CHAPTER 5 INTACT STABILITY GZ CURVE AREA CRITERION NOT MET FOR OPERATING DRAFT WITH FULL PASSENGER LOAD — METACENTRIC HEIGHT GM CALCULATED AT 0.42 M AGAINST ABS MINIMUM 0.60 M FOR PASSENGER VESSELS — USCG STABILITY LETTER ISSUED IN ERROR — USCG INSPECTION FINDS DEFICIENT STABILITY BOOKLET — VESSEL ORDERED OUT OF SERVICE 34 DAYS — $285,000 LOST REVENUE AND REMEDIATION COSTS. A San Francisco Bay passenger ferry operator commissioned a naval architect consultant to prepare a stability analysis and booklet for a new high-speed passenger ferry certificated for 250 passengers under a USCG Certificate of Inspection. The stability analysis was prepared and a stability letter was issued by a person holding a USCG Merchant Mariner Credential (master license, near coastal) but no BPELSG PE-NA designation (BPELSG confirms no PE-NNNNN PE-NA for the defendant). ABS Rules Part 3 Chapter 5 requires a minimum GM of 0.60 m for passenger vessels at all operating loading conditions including the full passenger load departure condition. The consultant calculated GM at 0.42 m for the maximum passenger load departure condition, below the ABS minimum. The GZ righting lever curve for the full passenger load condition failed to achieve the ABS minimum area criterion of 0.055 m·rad under the righting lever curve to 30° due to the inadequate initial stability. The stability letter was issued certifying adequate stability without identifying the ABS minimum GM deficiency. A USCG Port State Control inspection reviewing the vessel’s Certificate of Inspection renewal documentation identified discrepancies between the stability booklet loading conditions and the ABS intact stability criteria. The USCG Sector San Francisco ordered the vessel out of service pending stability booklet correction and independent stability verification. The vessel was out of service for 34 days, losing the revenue from its regular passenger route while a licensed PE-NA performed corrective stability calculations. Total lost revenue and remediation costs were $285,000. The ferry operator retained a licensed PE-NA to opine on the stability analysis deficiency and the ABS GM minimum criterion violation.
• UNLICENSED MARINE ENGINEER CALCULATES MOORING LINE LOAD FOR CONTAINER VESSEL BERTH AT PORT OF LONG BEACH WITHOUT PE-NA — ABS RULES PART 7 CHAPTER 1 ENVIRONMENTAL LOAD COMBINATION (WIND + CURRENT + WAVE) NOT APPLIED — MOORING LINE BREAKING LOAD UNDERSPECIFIED BY 30% — STORM EVENT — TWO MOORING LINES PART — VESSEL SURGES 6 FEET ALONG DOCK — DOCK FENDER SYSTEM STRUCTURAL DAMAGE — PORT OF LONG BEACH EMERGENCY REPAIR — $195,000 INFRASTRUCTURE AND LEGAL COSTS. The Port of Long Beach contracted for the engineering design of a mooring analysis for a new dedicated container terminal berth to accommodate Panamax container vessels (LOA 294 m). The mooring analysis was prepared and stamped by a person holding a Civil Engineer (PE-CE) license but no BPELSG PE-NA designation (BPELSG confirms PE-NNNNN PE-CE only, no PE-NA for the defendant). ABS Rules Part 7 Chapter 1 mooring system design requires application of the combined environmental load: wind load (from the governing beam wind angle, calculated per ABS wind pressure formula with vessel above-water profile area), current load (calculated per ABS current drag formula with wetted underwater profile), and wave load (mooring line quasi-static surge and sway load from regular wave action at berth). The PE-CE consultant calculated the mooring line breaking load requirement considering only wind load from one direction, omitting the vector-combined wind + current + sway load combination required by ABS Part 7. The underspecified mooring lines (WLL 85 tonnes specified vs. the ABS-compliant 113 tonnes required) were installed. During a Santa Ana wind event with 40-knot beam winds combined with a 2-knot port entry current, two mooring lines on the vessel’s stern parted at the synthetic rope-wire rope junction. The vessel surged approximately 6 feet along the dock, displacing two dock fenders from their pile-mounted guides and damaging the rubber fender unit mounting hardware. Port of Long Beach emergency response, fender repair, and investigation costs were $195,000. The Port retained a licensed PE-NA to opine on the mooring load calculation deficiency and the causation of the line parting event.
• UNLICENSED PE STAMPS PLEASURE YACHT STRUCTURAL DESIGN WITHOUT PE-NA — SNAME BULLETIN 3-60 HULL STRUCTURAL FINITE ELEMENT ANALYSIS NOT PERFORMED FOR 65-FOOT SAILING YACHT DECK/CABIN STRUCTURAL INTERSECTION — INADEQUATE LAMINATE THICKNESS FOR MAST BASE COMPRESSION LOADS — CALIFORNIA STATE LANDS COMMISSION MARINE PATROL INSPECTION FINDS STRUCTURAL DEFICIENCY — VESSEL REQUIRED OUT OF STATE WATERS — $95,000 REMEDIATION AND TRANSIT COSTS. A custom yacht builder commissioned a structural engineering review and stamp for a 65-foot ocean-going sailing yacht designed for offshore racing and California coastal cruising. The structural design package was stamped by a person holding a Mechanical Engineer (PE-ME) license but no BPELSG PE-NA designation (BPELSG confirms PE-NNNNN PE-ME only, no PE-NA for the defendant). SNAME Technical Bulletin 3-60 Section 5.1 requires finite element analysis for critical hull structural connections where load paths are complex, including the mast base/deck/cabin trunk structural intersection on sailing vessels, where the mast compression load (typically 80,000–120,000 lbs for a 65-foot mast) is transferred through the mast collar into the deck laminate and framing. The PE-ME consultant performed simplified beam section calculations without conducting the SNAME-required FEA of the mast base deck panel, underestimating the deck panel stress concentration factor at the mast collar by approximately 35%. The specified laminate thickness was insufficient for the governing load case of mast compression under spinnaker flying in 25-knot apparent wind. California State Lands Commission Marine Patrol officers, responding to a dockside complaint about visible deck distortion at the mast collar, conducted a marine inspection and observed cracking and delamination in the deck structure at the mast base area. The California State Lands Commission ordered the vessel to leave California state waters pending structural repair and certification by a licensed PE-NA. Transit and remediation costs totaled $95,000. The yacht owner retained a licensed PE-NA to opine on the structural design deficiency and causation of the deck delamination.

Distinct From Mechanical Engineer (§ 6701 PE-ME), Civil Engineer (§ 6730 PE-CE), Structural Engineer (§ 6736 SE), and Petroleum Engineer (§ 6701 PE-PE)

• DISTINCT FROM Mechanical Engineer (Bus. & Prof. Code § 6701 PE-ME designation) — A Mechanical Engineer (PE-ME) is licensed to perform HVAC system design, process piping engineering, pressure vessel design, and mechanical equipment engineering; a Mechanical Engineer may not stamp vessel hull stability analyses, ship structural designs, or mooring system load engineering documents requiring naval architecture expertise; a Naval Architect & Marine Engineer (PE-NA) may not stamp HVAC system designs, process piping calculations, or land-based mechanical equipment specifications: PE-ME and PE-NA are separate BPELSG module designations requiring separate PE branch examinations; the § 6701 (PE-NA) fee petition requires confirming absence of PE-NNNNN with PE-NA designation for naval architecture services, not PE-ME designation.
• DISTINCT FROM Civil Engineer (Bus. & Prof. Code § 6730 PE-CE) — A Civil Engineer (PE-CE) is licensed to perform land-based civil infrastructure engineering, site grading, drainage design, and civil site improvement; a Civil Engineer may not stamp vessel stability analyses, marine structural engineering documents, or USCG regulatory submittals requiring naval architecture expertise; a Naval Architect & Marine Engineer (PE-NA) may not stamp grading plans, drainage calculations, or civil site improvement engineering without PE-CE designation: PE-CE and PE-NA serve entirely different engineering disciplines; a marine terminal project may require both PE-CE-stamped land-side civil engineering and PE-NA-stamped vessel berth mooring engineering; neither designation authorizes the practice of the other.
• DISTINCT FROM Structural Engineer (Bus. & Prof. Code § 6736 SE) — A Structural Engineer (SE) is licensed to perform land-based building structural engineering, including seismic design, high-rise structural analysis, and bridge structural engineering; a Structural Engineer license does NOT authorize ship structural design, marine fatigue analysis, or naval architecture stability calculations; a Naval Architect & Marine Engineer (PE-NA) may not stamp land-based building structural designs, seismic force calculations, or bridge structural engineering without SE or PE-CE designation: SE and PE-NA serve entirely different engineering disciplines; SNAME Bulletin 3-60 ship structural design methodology differs fundamentally from ASCE 7 land-based structural engineering; USCG and ABS require PE-NA-stamped vessel structural documents, not SE-stamped documents.
• DISTINCT FROM Petroleum Engineer (Bus. & Prof. Code § 6701 PE-PE) — A Petroleum Engineer (PE-PE) is licensed to perform wellbore integrity engineering, drilling engineering, and reservoir engineering; a Petroleum Engineer may not stamp offshore platform vessel stability analyses, marine mooring system designs, or USCG vessel structural documents; a Naval Architect & Marine Engineer (PE-NA) may not stamp wellbore integrity reports, drilling engineering designs, or cementing engineering documents without PE-PE designation: PE-PE and PE-NA serve entirely different engineering disciplines; offshore oil and gas projects may require both PE-PE-stamped wellbore engineering and PE-NA-stamped vessel and marine structure engineering; neither designation authorizes the practice of the other.

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