100-200 GRT upgrade - how to educate the evaluator

Hi all - would like your thoughts on this - I submitted for an increase of 100 to 200 GRT near coastal, and just got back a letter requesting additional sea time.

The relevant CFR is 46 CFR 11.422(b) (2) which specifies an additional 90 days for master tonnage increase. NMC is referencing all of the other CFRs and required days for an ORIGINAL issuance at 200 ton which we all are familiar with. Even the lower level tonnages checklist on the NMC website correctly draws from 46 CFR 11.422(b) (2).

I submitted the required 90 days, as well as the required examination completion.

What’s the best way to educate the evaluator on the proper CFR reference?

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Ask for reconsideration of their decision. Use that word.

Note that the 90 days has to be in “the highest tonnage increment authorized by the master endorsement.” That means the tonnage of the 90 days has to be higher than the tonnage you used to get Master 100.

Don’t you mean it has to be above 50 GRT in this case? If all his previous time was on a 50 GRT vessel, he would still get the increase to 200 GRT with just 90 additional days.

By the way, I went through a reconsideration recently and it is painfully slow. Before you use that word, you should make another attempt at explaining to the evaluator the rule. Otherwise it has to go through many more layers and could take up to 4 more months.

You’re right. It would have to be over 50 GRT. Reconsideration takes about 30 days, or does on the ones I see on appeal of the reconsideration decision.

30 days I wish. Mine was a simple reconsideration filed back in June. I just got the response this month.

Yes - the additional 90 days in my case are all 76 GRT. That’s also how I interpreted the CFR. But interestingly, the NMC has a new checklist called NATIONAL LOWER LEVEL TONNAGE INCREASES § 11.422:

It shows the extra days from ZERO to the limit of current cert.

“If holding Mate 100 GRT (service on deck, any position):
• 45 days additional service on vessels of 0 - 100 GRT to increase to 200 GRT.”

It also includes a note that the checklist is not valid for master 100-200, which I interpret to mean because that increase requires the exam.

I can only assume that the evaluator is not familiar with the CFR nor this new checklist.

UPDATE - spoke to the evaluator, and it sounded like he was not specifically familiar with that upgrade path. He used the “reconsideration” word before I did and said it was already forwarded to his management. I drafted a nice letter and sent it in - we’ll see what happens. Thanks all…

Got the following message in an email last week regarding processing time:

“The National Maritime Center received your reconsideration request. The increased net processing time caused by the lapse in appropriations and partial government shutdown is impacting the reconsideration process. You should expect a decision within 90 days.”

I just renewed my license and I got my physical (I went ahead and renewed my medical card as well) on Oct 29th and got an email on Nov 5th stating my Medical Card has been mailed and an email on Nov 8th that my license had been mailed. I think that is the quickest turn around time I’ve ever had. I’m pretty sure most of the delays from the govt shutdown have been caught up.

I will never ask for another Reconsideration

Long before the government shutdown my successful request for Reconsideration took 11 months. Four months of the delay was caused by a suspension in processing requests for Reconsideration, so that the reconsideration staff could assist the evaluators with a backlog of applications.

My request for Reconsideration would never have been completed if someone from USCG headquarters hadn’t helped me. My request for Reconsideration was granted a couple days after headquarters got involved.

Use a good license consultant that speaks USCG language to do everything possible to educate the evaluator the first time around. Forget Reconsideration.

Coming up on 90 days on this application and still nothing other than the automated emails saying “30 days left to submit outstanding information” or the application will be withdrawn.

The application is under reconsideration due to an improper interpretation of the CFR by the evaluator - nothing left for me to submit…frustrating.

I submitted a comms ticket and got back “under review”. Any suggestions? Don’t want to hit the 90 days (in another week) and lose the app…

You were warned about the painfully slow reconsideration process. It taking place over the holidays doesn’t help.

Why not let the application die and submit another one. Or hire a consultant like Holly Chetta to get it all sorted out for you.

I just took another look at your original question and I think I have some bad news for you. You are looking to increase from 100 GRT to 200 GRT and you assumed that the rules in 46 CFR 11.422 applied:

(a) Each national endorsement as master or mate of vessels of less than 200 GRT is issued with a tonnage limitation based on the applicant’s qualifying experience. The tonnage limitation will be issued at the 25, 50, 100, or 200 GRT level. The endorsement will be limited to the maximum GRT on which at least 25 percent of the required experience was obtained, or 150 percent of the maximum GRT on which at least 50 percent of the service was obtained, whichever is higher. Limitations are as stated above, using the next higher figure when an intermediate tonnage is calculated. If more than 75 percent of the qualifying experience is obtained on vessels of 5 GRT or less, the MMC will automatically be limited to vessels of less than 25 GRT.

(b) The tonnage limitation may be raised as follows:

(1) For an endorsement as mate, with at least 45 days of additional service on deck of a vessel in the highest tonnage increment authorized by the officer endorsement.

(2) For an endorsement as master, with at least 90 days of additional service on deck of a vessel in the highest tonnage increment authorized by the master endorsement.

(3) With additional service, which, when combined with all previously accumulated service, will qualify the applicant for a higher tonnage officer endorsement under the basic formula specified in paragraph (a) of this section.

(4) With 6 months additional service in the deck department on vessels within the highest tonnage increment on the officer’s license or MMC endorsement. In this case, the tonnage limitation may be raised one increment.

Unfortunately, I believe that USCG considers the initial 100 GRT license as a completely separate endorsement than the 200 GRT license. The rules under 11.422 only apply if you receive a tonnage restriction on your 200 GRT license. For example, all hawsepipers generally start out with a 100 GRT license (it may be restricted to 25 or 50 GRT, but we’ll still call it a 100 GRT license). This is because it isn’t even possible to apply for a 200 GRT license (which also may be restricted to 25, 50, or 100 GRT) unless you have 180 days service as Master or Mate. Once you get your 100 GRT license and obtain another 180 days service as master or mate, you can again apply for a new 200 GRT license. But the upgrade rules of 11.422 don’t apply, as USCG sees the 200 GRT license as distinct from the 100 GRT license. It is even likely that when they issue you a 200 GRT licenses, it may be restricted in tonnage to 100 GRT or less).

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Do you currently hold a Master less than 200 GRT restricted to less than 100 GRT or do you have a 100 ton Master? They are two different licenses with two different upgrade paths.

I have a 100 GRT Master. My original was a 50, then upgraded that to a 100 under this CFR b(4). I have several hundred days since then. This could be interpreted both ways, including on the NMC checklist itself…

It says 100-200 upgrade as master does not apply as that is the only path that additional examination is required, which I’ve completed and submitted.

That checklist is for someone that holds a license as master or mate less than 200 GRT issued under 46 CFR 11.424, 425, 426, or 427 that has a tonnage limit on it. They met all the sea time requirements for Master 200 GRT but just didn’t have time in tonnage so had a tonnage restriction.

Your license does not qualify since you got Master less than 100 GRT issued under 46 CFR 11.428 and need to meet the full requirements for Master less than 200 GRT shown below.

Interesting. All good information.

But then why did I get increased from 50 to 100 under 46 CFR 11.422 b(4)? (the “one-bump rule”…)

The tonnage rules of 11.422 apply to the less than 100 GRT license as well, but only up to 100 GRT. It isn’t possible to increase the 100 GRT license without meeting the separate requirements for a 200 GRT license. It is confusing and doesn’t make a lot of sense, but essentially CG treats a 100 GRT license and a 200 GRT license limited to 100 GRT as completely separate endorsements as far as advancing in tonnage even though both convey the same privileges as far as operating a vessel.

In fact, since CG last revised the rules, I believe it is now easier for a 100 GRT master to jump straight to 500 GRT endorsement, bypassing the 200 GRT license completely. The only additional complication with the 500 GRT license is you are required to take a course for basic and advanced firefighting and you have to complete a full test at the REC. Firefighting isn’t required for the 200 GRT endorsement and there is only an additional module or two of testing required.

This assumes you have enough time on vessels over 50 GRT.

Watch out.

Once the NMC starts telling you that you have only so many days to submit additional material to complete your application, they will kick your application out if you don’t send them additional material.

It happened to me when my application was complete, but my consultant did manage to get it reversed.