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.

http://www.dco.uscg.mil/Portals/9/NMC/pdfs/checklists/mcp_fm_nmc5_39_web.pdf

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