Shipyard sea time

I have read through Policy 09-01 and cant quite find what I need.
Working on a new build project where the vessel is not in operation, or is service mandated by the COI. Does any of the time count? 3 for 1, up to 180 days. I am trying, just dont see it.
I think the CG response will be black and white…"Sea service begins when the vessel is underway."
Looking for a loophole.

Well, not sure if this is a definitive answer, but I found it in the Marine Safety Manual, Chapter 2, page 2:

Service On Vessels Other Than Underway.
46 CFR 10.213© discusses the application of a 25% credit factor for periods of assignment to vessels at times other than underway. Creditable sea service for this category applies to vessels, whose sea service has not been previously used, that spend the vast majority of their time moored. An example, would be a submarine tender or a vessel undergoing an extended shipyard visit. The vessel status would not be reflected on the Record of Sea Service but might be established during the evaluator’s interview of the applicant.

I spent some time researching this as well and it’s as close as I could come to an answer…I would think that a 3 for 1 would be more in order rather than the 25%