Frustration is building (again)

Anchor- I guess I did ask a stupid question didn’t I. That is too funny. Duh, guess I should wait until I have a coffee before I ask stuff like that.

Ok, so I don’t have any patience. I am curious as to how many members who have a 1600 Master with a application in for 3rd Mate that have received the reply that they have to take the OICNW STCW classes? Did you appeal the response? I am getting ready to send an email to Rear Admiral Watson (Prevention Policy Directorate (CG-54)) and would like to have a rough estimate number of mariners who are experiencing this problem in hope of getting it resolved in a timely manner (at least somewhat). Drop me a PM if you want.

Thanks - Brian

I am one such person…my evaluator is Abigail Cochenour. Put me on the list. If you need more info let me know. I have written her my response and am waiting to get her response to my response…

Send it to RDML Kevin Cook. He relieved Admiral Watson last month.

Thank you very much Mr. Cavo.

[quote=Capt Brian;17524]Ok, so I don’t have any patience. I am curious as to how many members who have a 1600 Master with a application in for 3rd Mate that have received the reply that they have to take the OICNW STCW classes? Did you appeal the response? I am getting ready to send an email to Rear Admiral Watson (Prevention Policy Directorate (CG-54)) and would like to have a rough estimate number of mariners who are experiencing this problem in hope of getting it resolved in a timely manner (at least somewhat). Drop me a PM if you want.

Thanks - Brian[/quote]

Brian,
When I had my 1,600 ton Master and applied for an upgrade, the same thing happened to me. Stewart Walker then told my evaluator that I did not have to take all of the courses and I was approved. The evaluator was Norleen.
I know at least 8-10 people that have upgraded since, just at Edison Chouest Offshore, from the Large OSVs, with no problem at all.
You can have my information if you want, and use me as an example of an Unlimited Master that used this exact career path; and I’ll get with the guy that I work with (he’s in the rack now), for his information. He was just evaluated 3 weeks ago and was told he would have to take all of the courses.

Ok, I have read and re-read, and re-re-read policy letter 02-03 and have gone over 46 CFR 10.205 (l)-(m) and 46 CFR 10.903© and see absolutely no place where I have take the OICNW courses and assessments if I already hold a “valid” license issued prior to 1998.

When I called the NMC again today I explained my situation, what certificates/licenses I held, and I was told “Ok, so what is the problem with your OICNW?” When I explained that my application was denied I was told by the call center operator that my denial went several paygrades above him and that if I was told to appeal, I should as he could not explain discrepencies between one mariner and the other.

My appeal letter to date contains each piece of email between the NMC and myself regarding this issue, a copy of my degree from the Academy, a copy of my license, RFPNW STCW cert, BST/BRM/ARPA certs, and hopefully a more mild letter to CAPT Stalfort et al (copied to a multitude of Congressional folks) than I have sitting on my drive right now!

Time will tell.

[quote=kzoo pilot;17558]Ok, I have read and re-read, and re-re-read policy letter 02-03 and have gone over 46 CFR 10.205 (l)-(m) and 46 CFR 10.903© and see absolutely no place where I have take the OICNW courses and assessments if I already hold a “valid” license issued prior to 1998.

When I called the NMC again today I explained my situation, what certificates/licenses I held, and I was told “Ok, so what is the problem with your OICNW?” When I explained that my application was denied I was told by the call center operator that my denial went several paygrades above him and that if I was told to appeal, I should as he could not explain discrepencies between one mariner and the other.

My appeal letter to date contains each piece of email between the NMC and myself regarding this issue, a copy of my degree from the Academy, a copy of my license, RFPNW STCW cert, BST/BRM/ARPA certs, and hopefully a more mild letter to CAPT Stalfort et al (copied to a multitude of Congressional folks) than I have sitting on my drive right now!

Time will tell.[/quote]

Like I said, you have to e-mail them to death before you get any response. I know of several files I worked on that my higher-ups said “no” and as soon as those pinheads heard from the mariner’s Congressman the regs suddenly changed and it was given to them. If you need anyone else’s e-mail besides the ones I have posted on here, let me know.

NMC 01-02 Section 11 paragraph (d) …No further testing is required.
[U]That section is no longer valid.[/U]

Paragraphs (a), (b), © & (e) specifically state “Effective 1 February 2002”. Paragraphs[B] (d) and (f) were only good until 1 February 2002[/B] so they are now obsolete.

The dream I had of no testing was squashed when I received the above reply from the NMC a couple of years ago. I have been satisfied with turning in my assesments and testing (paragraph c) since then. But now I see some are having problems with that.

Also if you don’t already know NMC Policy Letter 16-02 has corrections to be applied to NMC 01-02. They had little effect from what I need to do but it may effect others.

Oh yea,
NMC 16-02 also had the phantom assesment sheet OICNW 02-03C

[quote=Capt ETC;17655]NMC 01-02 Section 11 paragraph (d) …No further testing is required.
[U]That section is no longer valid.[/U] [/quote]

This statement is incorrect! I was in contact with Norleen Schumer and this was what she told me:

"I have recently (February of this year) fought this battle and I like to think I won (at least so far).

Here is the response I received from NMC:

Paragraph 11(d) is back in place. If you know mariners which were denied and should not have been, tell them to contact their evaluators.

The problem is, (and I suggest you put this in your letter to the Admiral) that this type of information IS NOT DISSEMINATED to the folks that actually do the work, i.e. the evaluators, much less the Mariner’s who are the ones that pay the price for lack of communication and training for those who work at the NMC.

Please make sure you let all of your fellow mariners know also."

I have read Policy Letter 16-02 and it does not “touch” Enclosure 1, Paragraph 11(d).

[quote=Capt Brian;17666]This statement is incorrect! I was in contact with Norleen Schumer and this was what she told me:

"I have recently (February of this year) fought this battle and I like to think I won (at least so far).

Here is the response I received from NMC:

Paragraph 11(d) is back in place. If you know mariners which were denied and should not have been, tell them to contact their evaluators.

The problem is, (and I suggest you put this in your letter to the Admiral) that this type of information IS NOT DISSEMINATED to the folks that actually do the work, i.e. the evaluators, much less the Mariner’s who are the ones that pay the price for lack of communication and training for those who work at the NMC.

Please make sure you let all of your fellow mariners know also."

I have read Policy Letter 16-02 and it does not “touch” Enclosure 1, Paragraph 11(d).[/quote]

So if you meet all the STCW requirements you no longer have to test? I tried to argue this one several months ago, and was told I had to test, that this didn’t any longer apply.

It depends on when you received your 1600 Master license weather you need to test or not and do the assessment of skills. Paragraph 11© or 11(d) will apply to you depending if you received 1600 Master before 1 August 1998 or not. Hope this helps out.

I hope it is, this was one of the few replies I got back that answered my questions specifically by someone who knew the policy letter. But now it seems it was wrong.

I was laughed at when I asked the N.O. REC if I read the paragraph correctly that I didn’t have to test.
Since then I’ve been trying to get my assesments signed off, which took me almost 3 years because there was no pencil whipping, and just recently finished. I’ve dusted off all my study material and started on that. I’ll be turning in my application when I get in and the anticipation of a windfall or punch in the gut is going to kill me.

Ok, now I am REALLY confused. My read was that for and upgrade in tonnage/route, the testing and assessments applied, but for issuing an OICNW cert on an EXISTING license, you would only need to take the BRM/ARPA/BST . . .

Again, we have an issue of different evaluators, different mariners, different answers. What a mess.

I got my 500 Master in 1990, but didn’t get my 1600 Master until after '98. I think I got the 1600 Mate before '98 but I don’t remember now because now it’s 2009 and my brain is much older and dustier.

I have completed a rough draft of a letter to NMC addressing PL 01-02.I would welcome any comments,or criticism.Thank You…

[B]Dear Sir :[/B]

[B]I am a merchant Marine officer that currently has asked for a [/B][B]reconsideration on an application that is on file with your office. Part of the [/B][B]reconsideration I am asking for is a clarification of USCG Policy letter [/B][B]01-02. As you must be aware there have been many different interpretations[/B][B] to this policy letter, particularly in regard to section 11(d).[/B]

[B]Policy Letter 1-02 <http://www.uscg.mil/nmc/marpers/pag/1-02.pdf> :[/B][B]Enclosure (1) Paragraph 11(d): (Raise of Grade OR Increase in Scope)[/B][B]An applicant who holds either a 500 GRT or 1,600 GRT license and STCW[/B][B]Certification that were based on service that began on or after 1 August[/B][B]1998 and wishes to apply for a third mate’s license must acquire sea service[/B][B]Required by 46 CFR 10.402 and 10.407. No further testing or assessments are [/B][B]required.[/B]

[B]Through this age of instant communications, and internet blogs, the fact that this policy is interpreted inconsistently is indisputable, and among Professional Mariners is the subject of much aggravation .The forum of gcaptain.com is rife with examples of many mariners with identical credentials and applications receiving an unconditional approval for this upgrade, or a flat denial, the only apparent difference being the evaluator that was processing the application.[/B]

[B]The consensus among mariners is that the obvious intent of Line 11(d) was to give credit the professional mariner with the experience they have rightly earned by reaching the level of experience of 1600GRT Master, and allowing a seamless transition to 3rd Mate AGT. This also seems to be the original intent of CFR 46 10.407 3c. To interpret the intent of this paragraph any other way does not make sense. Any other interpretation says in essence that a 500GRT or 1600GRT Master does not comply with STCW standards and does not qualify to stand a navigational watch on his own Vessel.[/B]

[B]I am aware of course that this is only an opinion, and that is precisely why I feel that this policy letter should be amended or otherwise clarified to eliminate this ambiguity, so that the policy can be applied consistently and fairly to everyone. Thank you for your time and attention to this matter.[/B]

[B]Respectfully submitted,[/B]

Please post the reply, you are not the first one to write a letter

Home for a few days and I was really hoping to hear from the NMC concerning my appeal by now; no dice. I am planning on calling my evaluator tomorrow or Thursday but when I contacted them by email a few weeks ago I was informed that " appeals are handled in the order they are received". My 90 days is ticking . . .

Still no word. I sent an email today querrying my appeal progress. I forwarded the email from the NMC that they sent when my appeal letter was dug out of the mail room and sent to the technical office for review. The date of that email was 9-14. I didn’t think it would take a month!