[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.