[QUOTE=CaptAndrew;134257][I]As far as I know[/I] Arpaa is still only required for an equipped vessel. So you are correct. How to convince the evaluator is another matter. Ask for the supervisor and ask for documentation or references to show it IS required, The most recent checklist from MNC shows it as optional. While the checklist is not the actual law it is good supporting documentation. I have always submitted the checklist with my applications with appropriate boxes checked and exceptions highlighted.
I quoted the appropriate cfrs and such backing up about arpaa being optional. No joy. He told me I could sit for a 1600 ton mate, but that license would be limited domestically. I thought about just scrubbing the masters license and then just pursue the mate’s license but then I figured it wouldn’t be worth much without STCW, and I don’t know when I will be able to swing doing a arpa course. The mate’s license for STCW requires the OICNW. I then found out that I would have 11 total modules to test instead of 6 so I just settled for getting evaluated for the 500 ton master. I thought of filing an appeal but figured how things move so slow anyway to just let it go. I am currently working as an engineer and just wanted to upgrade my deck license to make myself more marketable in case. Utilizing sea time juggling deck and engine licenses is a little tricky also, I am figuring out.
It’s almost like you have to get a lawyer to interpret this all. For example, during my evaluation he challenged a sea letter I had from a past employer that listed me as a deckhand. I held an ab at the time. He said the letter had to be re written, that an ab is not the same as a deckhand. So my past employer, 9 years later re writes it for me. I then got told I have to get a letter of explanation from this company regarding why I was listed as a deckhand instead of ab! This all makes my head hurt if I think about it too much LOL