I’m trying to figure out if I can commercially tow with my 24’ boat without holding a USCG license. The USCG license is unavailable to me due to my citizenship status.
When I read the regulation (a) it seems that on towing vessels under 26’ in length the operator is not required to hold a license. When I read (b) it seems that if you are getting paid to do the tow (no mention of towboat length) then you need the license. Then there is an amendment that seems to add the length stipulation to item (b) but I’m not sure. Here is the text for 8904:
[I]TITLE 46 > Subtitle II > Part F > CHAPTER 89 > § 8904
§ 8904. Towing vessels
(a) A towing vessel that is at least 26 feet in length measured from end to end over the deck (excluding sheer), shall be operated by an individual licensed by the Secretary to operate that type of vessel in the particular geographic area, under prescribed regulations.
(b) A vessel that tows a disabled vessel for consideration shall be operated by an individual licensed by the Secretary to operate that type of vessel in the particular geographic area, under prescribed regulations.
Historical And Revision Notes
Revised section Source section (U.S. Code)
Section 8904 requires that a 26-foot or larger towing vessel be operated by a licensed individual for that type of vessel and for a particular geographic area. AMENDMENTS 1986 - Pub. L. 99-640 designated existing provisions as subsec. (a) and added subsec. (b).
EFFECTIVE DATE OF 1986 AMENDMENT
[/I]I live in an area with no commercial responders to aid private boats in need of assistance and find that I am doing a fair bit of that type of work on a gratis basis. I’d like to legitimize the service and set it up as a business. Am I good to go if I don’t exceed the towboat length limit?