I am currently in the process of dealing with the nmc on my application to add the dde endorsement onto my unlimited 2 ae license. However they have stated that I require additional testing. Looking at the marine safety manual vol III sect 12-5 there is a pathway for an academy graduate who has 60 days at sea to be given this without any further testing. In talking with my evaluator and her higher up (in appeal) they have stated that even though they have found nothing to contradict this they will still require testing. Furthermore, they have stated that they believe somewhere in the cfr’s contrics the msm. While talking with them I asked that they reference 46cfr sect 10.524 which deals with the dde and only differs with the msm in days 60 days vs 18 months. In my case days are over 1000 beyond the 60 or 18 month requirement. But they still are unrelenting!
Has anyone out there been down this road before?
Try explaining to them that all of the subject matter included in 46 CFR Table 11.950 for 2 A/E includes and supersedes that of the DDE. (DDE examination material contains only Practical and not Theoretical) You may need to file another appeal of the decision.
My Asst. Eng is currently going through this situation for his CE OSV. They are also telling him the same thing, all they gave him for reference was a list of requirements for a CE OSV which states you must hold a DDE or CE LMTD to obtain this endorsement. He explained that a second asst. test exceeds the testing requirements for the DDE Unlt, all they keep telling him is you still have to test. I think they just don’t get it and never will…
Its not as cut and dried as it seems, more details would help. When did you get your 3AE? Did you take the combined 3rd/2nd test or did you have to test for 2nd? Are you talking DDE 4000 or DDE Unlimited? Do you already have a limited DDE?
Unless they can quote the CFRs which supposedly contradicts the MSM it doesn’t matter what they “believe”. They may actually be right and just aren’t expressing it well. The MSM hasn’t been updated to reflect the combined 3/2 and 1/C tests. Personally, why waste the time with the appeal? I get the principle of it, I had almost the exactly fight with them last year, but just took the tests anyway. I spent one morning at the REC taking tests instead of months sending letters back and forth … your choice.
A ha!! It’s all your fault! You folded and took the tests and now they think they are correct and want everybody to take the tests! They more that take the test the more empowered NMC gets and now we have anarchy! (just joking)
[QUOTE=KPEngineer;79972]Its not as cut and dried as it seems, more details would help. When did you get your 3AE? Did you take the combined 3rd/2nd test or did you have to test for 2nd? Are you talking DDE 4000 or DDE Unlimited? Do you already have a limited DDE?
Unless they can quote the CFRs which supposedly contradicts the MSM it doesn’t matter what they “believe”. They may actually be right and just aren’t expressing it well. The MSM hasn’t been updated to reflect the combined 3/2 and 1/C tests. Personally, why waste the time with the appeal? I get the principle of it, I had almost the exactly fight with them last year, but just took the tests anyway. I spent one morning at the REC taking tests instead of months sending letters back and forth … your choice.[/QUOTE]
[QUOTE=Jeffrox;79999]A ha!! It’s all your fault! You folded and took the tests and now they think they are correct and want everybody to take the tests! They more that take the test the more empowered NMC gets and now we have anarchy! (just joking)[/QUOTE]
Yes, I admit it … I caved. I needed the Chief Ltd to get out from Dann Marine Towing. I didn’t have time to wait.
Dont worry though, I’m about to go through it again with my 1A/E and Chief Ltd Oceans … this time, I will not yield!
I had the same problem last year. NMC wanted me to take a one week DDE course before they would issue me a DDE Unlimited with the Chief OSV endorsement. I talked to about 5 different people at NMC, and they all had different things to say. I was about to cave and just take the test when someone told me to contact a licensing service. I did, and they got my credentials issued after a few phone calls and emails with the NMC. All it takes is someone that knows the rules like the back of their own hand to tell the evaluator what is what. The evaluators are just reading from a book that states all of the basic requirements for each license, and fail to use some common sense. As long as you’ve taken your 3rd/2nd test after a certain date, its in black and white that you are eligible for Chief limited without further testing. Good luck.
[QUOTE=gulf_engineer;80031] As long as you’ve taken your 3rd/2nd test after a certain date, its in black and white that you are eligible for Chief limited without further testing. Good luck.[/QUOTE]
You have to have taken your 3A/E BEFORE a certain date, not after. I think around 2002. To get the Chief Limited without further testing you have to actually be taking a 2A/E test when upgrading. If you took the combined 3/2 test and are getting the 2A/E without testing, then you have to test for Chief Limited and DDE. And just because it is in black and white doesn’t mean anything. That is the complaint.
Its not about knowing the rules, its about being able to speak the government language. You can’t talk about common sense with them. You have to be able to quote CFR and MSM references and you have to know which trumps which. Thats all your vaunted licensing service is going to do. You also have to get lucky and have an evaluator who wants to actually work with you. Mine didn’t and once he said “just write a letter and protest it” I caved. Time is money and the time wasn’t worth it for me.
I also ran into the same roadblock as KPengineer. I previously held a 2 A/E unlimited along with a C/E Near Coastal which had both expired. After going around and around with the evaluators, I too relented and realized that it’s just much easier to study for 12 modules than to deal with NMC sometimes.
I do fall under the new 2 AE/ 3 AE system. If it weren’t for the fact that numerous friends/colleagues of mine had this endorsement added (I have called about 15) without any trouble, I probably wouldn’t be so bothered by their stance. It’s just tough to grasp when you are speaking to an evaluator &/or there supervisor and they say " despite not having any documentation to the contrary of your argument we are still unable to approve your request for endorsement" !
Thanks for all the comments.