3rd A/E to 2nd A/E Unlimited

Can you upgrade from 3rd A/e Unlimited to 2nd A/E Unlimited solely with 360 days of seatime on a harbor tug, granted the tug is over 100Tons and 4000Hp?? If anyone knows or has been in that situation and done the upgrade I’d appreciate the info.


See 46 CFR 11.514 and 46 CFR 11.503(b).