3/M AGT - 1600 Master

Good Evening, I browsed around the forums before posting since I didn’t find a clear cut answer. I have a 3/M AGT from school, have sailed on ATB’s for 7years, would like to obtain some sort of addendum to the license since I don’t plan on going deep sea so can’t upgrade to 2/M. Question is this: What would the path to obtaining a 1600 ton Master NC / Oceans be? and for which modules will I need to study? Thanks for your time.

If the tug of your AT/B is over 200gt then you are able to upgrade to 2/M possibly with a tonnage restriction and maybe 1600gt Master by taking the 60 question crossover test. If its under 200gt then you are out of luck as all of the time needs to be on a boat over that tonnage.

Search the NMC website or crack the CFRs, it’s all there…

If your tug isn’t over 200 GRT you should still qualify for a 1600 ton master but you will need to take all seven modules (almost identical to the mate exam you took).

[QUOTE=“Capt. Phoenix;112519”]If your tug isn’t over 200 GRT you should still qualify for a 1600 ton master but you will need to take all seven modules (almost identical to the mate exam you took).[/QUOTE]

In fact, on an ATB you can count the tonnage of the barge for half your sea time so you should be able to upgrade to a 2M with no tonnage restrictions.

Hmmm… Kind of in the same situation. The tug is 593 GT and the barge is 4040 GT. The caveat I heard was because it is an ATB as opposed to an ITB only the tug time counts. Never thought about getting a restricted 2nd… Didn’t know it was an option. Sure would rather only take a 60 question instead of the whole shebang.

[QUOTE=“Siberfire;112526”]Hmmm… Kind of in the same situation. The tug is 593 GT and the barge is 4040 GT. The caveat I heard was because it is an ATB as opposed to an ITB only the tug time counts. Never thought about getting a restricted 2nd… Didn’t know it was an option. Sure would rather only take a 60 question instead of the whole shebang.[/QUOTE]

Look through the threads here. JDCavo posted details on how to use barge tonnage for an ATB. It’s a 2 for 1 sea time credit (2 years onboard counts as 1 year if sea time) and you can only use it for half your sea time. Apply for second mate and 1600 ton master at the same time and see what happens.

It all checks out. I have time for a restricted second mate and 1600 master… Oh wait, but only great lakes/inland time so no go.

Since the time requirements are so mixed up, you may be able to use or get some NC time on your AB ticket to meet the minimum requirements. If you are looking for a job in the oil patch, go for a 500 Master/Mate w/3000 ITC. Do not make any assumptions based on logic as far as the USCG is concerned. Plus if you do not like the answer that you get from the USCG then hang up, and call right back you may get a different person and different answer. Good Luck.

Thanks for replies all. Have a good weekend and Happy Fathers Day.

I had heard that some have tried that but didn’t know if it was true or not. I would imagine that the seatime letter you get from your company should definitively state that the vessels are a combined unit and how they are connected? Either way that’s a good piece of info to know.

Here we go again. This is not correct. See: 46 CFR 11.11(d): (note, NVIC 02-81 defines a “Dual Mode ITB” as what we call an ATB today).

“(d) Service on a Dual Mode Integrated Tug Barge (ITB) unit is creditable for original or raise of grade of any deck officer endorsement. Service on a Dual Mode ITB with an aggregate tonnage of over 1600 gross tons is creditable on a two-for-one basis (two days experience equals one day of creditable service) [B][I]for up to 50 percent of the total service on vessels over 1600 gross tons required for an unlimited officer endorsement. The remaining required service on vessels of over 1600 gross tons must be obtained on conventional vessels or Push Mode ITBs.”[/I][/B]

There is similar layman’s guidance on the NMC website as well.

By the numbers: For an unlimited upgrade you are required to have at least 180 days on vessels >1600T (and 180 on vessels 200-1600T). So at 2:1 you can use ATB time for up to half of the former (half of 180, NOT half of all the total time)… so, 90 days after 2:1. Yes, you can use another 180 days at 1:1 for the 200-1600T time, but it will always leave you 90 days short of real >1600T time. In other words, 360 ATB days will give you 270 days towards an unlimited upgrade, but the remaining 90 MUST be on a vessel >1600T.

270 days is the most amount of time you can ever credit towards an unlimited upgrade on an ATB. You can’t have your cake and eat it too.

I have heard of people that snuck through the system purely on ATB time, but it is not legal and only possible through the ignorance of the NMC.

[QUOTE=Capt. Phoenix;112534]Look through the threads here. JDCavo posted details on how to use barge tonnage for an ATB. It’s a 2 for 1 sea time credit (2 years onboard counts as 1 year if sea time) and you can only use it for half your sea time. Apply for second mate and 1600 ton master at the same time and see what happens.[/QUOTE]

You could also make a plausible argument that the towing unit is a “conventional vessel.” 46 CFR 11.211(d) does not specify that the “conventional vessel” cannot be part of an ATB.

Since the tug unit’s tonnage is over 200 GRT, you could argue that this time also be used for 2nd Mate AGT. As half your time (discounted at 2:1) can be from the aggregate tonnage, and that aggregate is over 1600 GRT, you could argue that qualify for 2nd Mate without a tonnage limit with at least 540 days on this ATB.

[QUOTE=wafinator;112718]… So at 2:1 you can use ATB time for up to half of the former (half of 180, NOT half of all the total time)… so, 90 days after 2:1. [/QUOTE]

This isn’t correct. 46 CFR 11.211(d) allows the aggregate tonnage to be used for up to 50% of the total required. The “half” is eafter being discounted at 1 for 2, so you can use 360 days total on the ATB for the aggaregate tonnage, discounted to 180 days (half) of the total required for 2nd Mate of 360 days.

[QUOTE=wafinator;112718]…270 days is the most amount of time you can ever credit towards an unlimited upgrade on an ATB. You can’t have your cake and eat it too.

I have heard of people that snuck through the system purely on ATB time, but it is not legal and only possible through the ignorance of the NMC.[/QUOTE]

See my hypothetical argument above. While that argument may not be what the Coast Guard intended, it’s a common legal concept that regulations, contracts, etc. are to be construed against the drafter and in favor of the other party. So while it’s not what we intended, it may be the appropriate interpretation. The Coast Guard also can’t have its cake…

As far as the origin of misapplication of regulations on ITB sercvice, it isn’t the NMC, it was common at some RECs long bnefore NMC. Some RECs also allowed inland mariners to get unlimited licenses based on the aggregate tonnage of their river tows.

[QUOTE=jdcavo;112757]

This isn’t correct. 46 CFR 11.211(d) allows the aggregate tonnage to be used for up to 50% of the total required. The “half” is eafter being discounted at 1 for 2, so you can use 360 days total on the ATB for the aggaregate tonnage, discounted to 180 days (half) of the total required for 2nd Mate of 360 days.
[/QUOTE]

Mr. Cavo, thanks for chiming in as always! I just don’t see it though. 46CFR 11.402(a) defines the service requirement for unlimited licenses as 50/50, 200-1600T and >1600T. 11.211(d) states “50 percent of the total service on vessels [B]over 1600 gross tons required [/B]for an unlimited officer endorsement.” To me, the “over 1600 gross tons” category requires 180 days and that is what is being referred to, half of that specifically. If it meant total overall service, why the qualifier about over 1600T?

Furthermore, the last sentence regarding “remaining required service on vessels over 1600 gross tons”. If it was intended for ATB time with a tug less than 1600t to count as 100% of the service, specifically 100% of [I]that[/I] service, what remaining service is there and why would they feel the necessity to define how to get it? It would be moot. The last sentence seems to reinforce my interpretation, no?

Ive always turned to your interpretations before, but I might need a little more convincing this time.

[QUOTE=wafinator;112781]Mr. Cavo, thanks for chiming in as always! I just don’t see it though. 46CFR 11.402(a) defines the service requirement for unlimited licenses as 50/50, 200-1600T and >1600T. 11.211(d) states “50 percent of the total service on vessels [B]over 1600 gross tons required [/B]for an unlimited officer endorsement.” To me, the “over 1600 gross tons” category requires 180 days and that is what is being referred to, half of that specifically. If it meant total overall service, why the qualifier about over 1600T?

Furthermore, the last sentence regarding “remaining required service on vessels over 1600 gross tons”. If it was intended for ATB time with a tug less than 1600t to count as 100% of the service, specifically 100% of [I]that[/I] service, what remaining service is there and why would they feel the necessity to define how to get it? It would be moot. The last sentence seems to reinforce my interpretation, no?

Ive always turned to your interpretations before, but I might need a little more convincing this time.[/QUOTE]

The provision that the aggregate tonnage can be used for up to 50% refers to the aggregate service after it has been adjusted, not before. So you can get 180 days of credit from the aggregate tonnage, you just need to show 360 days to get it.

For the remainder, the regulationsays it must be on conventional vessels. The tug unit (alone) is a “conventional vessel.” So if it is over 200 GRT, it couldbe used for the balance of the time for an any gross tons license. I’m pretty sure the Coast Guard did not intend this, but the strict reading of what we wrote would allow it. By general rules of legal interpretation, we have to accept that interpretation as we drafted the regulation. A conflict of multiple interpretations is usually resolved against the party that drafted the regulation or contract. So, we should have said “conventional vessels that are not part of an ITB or ATB.” The error in the drafting is that it treats an ITB/ATB as a single vessel, and it’s not.

http://www.uscg.mil/nmc/professional_qualifications/pdfs/crediting_sea_service.pdf#page12

The NMC “guidance” is even more confusing. It says ATB time can be used, at 2:1, for up to 90 days (half) of the >1600t time, but like you said, can also count as a conventional vessel? But at what tonnage, aggregate? It doesn’t exactly specify. For the 200-1600t time of course, 1:1 for all 180 required, but to me it leaves doubt as to where that other >1600T 90 comes from and why they chose to write it the way they did. Seems like a pretty funky system without any real logic (2:1 for 90, 1:1 for essentially 270?). But hey, as long as there is a consistent application of the interpretation that you speak of, thats great. They could make the guidance a wee bit clearer.

For the lazy:
“Example: A mariner wanting a raise in grade from 3rd Mate to 2nd Mate using time on Dual Mode ITBs can be credited on a 2 for 1 basis for up to 90 days to meet half of the requirement of service needed over 1600GRT. If a mariner submits all time on Push Mode ITBs, time can be credited as equivalent to a conventional vessel.”

I guess that is the great thing the NMC’s guidance is their interpretation of the rules. Fortunately for us we can interpret the rules in a different way. As Mr. Cavo has pointed out, the law/rule/contract usually is interpreted in favor of the party whom did not write the rule poorly in the first place.

All in all… My time is still on the great lakes and not near coastal so my excitement has been for nought.