Acquiring Near Coastal seatime on Towing Vessels?

I am looking to get a better understanding of acquired Near Coastal sea time in the towing industry. Can someone explain how there are so many captains out there in the industry that have Near Coastal 1600 ton Master licenses and rarely go offshore. Is it not true that the required sea time according to the CFR’s would be 1440 days of which half MUST be Near Coastal. That is a lot of “Outside the Boundary transiting” for some of these vessels that hardly ever go past the entrance buoys. Is it the way sea service letters are presented to the USCG. Can companies put that a unit is involved in coastwise trade on a sea service letter and as long as the vessel is registered to transit outside the boundary and makes a few trips then the requirment is met? Am I missing something?

I ask this because it seems that the NMC is looking more in depth to sea service letters with respect to how Near Coastal time was acquired, such as exact amount of days outside the boundary. Could it be that when the REC handled licensing, this issue was overlooked and if they were to look at a Sea Service Letter that said “vessel is involved in coastwise trade” then that satisfied the requirement? I just dont understand how Captains on Towing Vessels that operate predominately in Inland waters were able to acquire Near Coastal Licenses.

[I]‘I ask this because it seems that the NMC is looking more in depth to sea service letters with respect to how Near Coastal time was acquired,’

[/I]So I’m interested too but from a STCW/Renewal perspective. Captain at my company is now being told that he has to show ‘coastwise’ time in order to NOT attend STCW refresher course. I thought all of this was solved with the little ditty now presented in Sea Service letters [I]‘participates in Company required training drills and safety meetings’[/I]
Now I’m hearing that we’re gonnna have to demonstrate/prove were coastwise? How the fack are we to do that? What, CG doesn’t have ENOUGH paper to sift through already?

Somebody make me smarter, Please

Get a hold of the vessels position log and start xeroxing

See THAT’S what I mean, are they (CG) prepared for the snowstorm of paper? It’s absurd!

Keep a Daily log for yourself along with the ships log. Its the only way we can keep up anymore. Atleast quarterly get your company to sign off on your log. Its some extra work but it seems to be what we have to do now.

Of course asking the old man to get a few books of discharges from the CG to fill out and sign each time you go home would be too much of an inconvenience, along with sending in the white copies to NMC.

This might eventually go electronic once the new credential comes out from what I understand, but it’s what it was intended for unless you’re getting a sea-time letter from your employer.

I keep an MSExcel spreadsheet log of EVERY time I’m moving through the water with a barge. Yer thinking that if I have Company sign off on it that it will suffice? Has Mr. Cavo commented on this anywhere else?

The renewal papers from the USCG reads that sea service must state who, what, when, and where. Mine have never covered all that and and still don’t. Maybe my paperwork is about to be kicked back too - I can hardly wait! My sea service letters from ECO even state something to the effect of :“this letter is not formatted IAW USCG guide lines”.