Two different approaches(Fig. 1)are compared here for assessing owT natural frequency and perma nent accumulated pile rotation: (1) The average maximum horizontal mudline force(H) and mudline moment(M) from the stochastic time histories used with a p y curve pile-spring system including embed- ment reduction, (2) Rainflow counts of the time histories were used to idealize the stochastic time histories into load parcels of(H, M, N) and were used in conjunction with the cumulative cyclic degra- dation method proposed in Section 4 The pile design in this paperconsists of a 6 m diameter pile with wall thickness of 0.09 m embedded 34 m into homogeneous clay with submerged unit weight of 9.2 kN/m