I am looking to get a better understanding of acquired Near Coastal sea time in the towing industry. Can someone explain how there are so many captains out there in the industry that have Near Coastal 1600 ton Master licenses and rarely go offshore. Is it not true that the required sea time according to the CFR’s would be 1440 days of which half MUST be Near Coastal. That is a lot of “Outside the Boundary transiting” for some of these vessels that hardly ever go past the entrance buoys. Is it the way sea service letters are presented to the USCG. Can companies put that a unit is involved in coastwise trade on a sea service letter and as long as the vessel is registered to transit outside the boundary and makes a few trips then the requirment is met? Am I missing something?
I ask this because it seems that the NMC is looking more in depth to sea service letters with respect to how Near Coastal time was acquired, such as exact amount of days outside the boundary. Could it be that when the REC handled licensing, this issue was overlooked and if they were to look at a Sea Service Letter that said “vessel is involved in coastwise trade” then that satisfied the requirement? I just dont understand how Captains on Towing Vessels that operate predominately in Inland waters were able to acquire Near Coastal Licenses.