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.