ATB's qualify as unlimited tonnage?

I’ve heard a rumor that ATB’s tonnage is now calculated with their respective barges, giving Mariners unlimited sea time. I’ve searched the forums and am to lazy to look it up in the cfr’s. Anyone confirm this?

Yes thats true. But i think as far as seatime you get 2 for 1 days on an ATB.

About ten seconds with Google on my phone:

As of changes in “2013”:

If the aggregate tonnage of the tug and barge is over 1600 gross registered tons (GRT), service is creditable on a two for one basis (two days experience equals one day of creditable service) for up to 50% of the total service on vessels over 1600 GRT required for an unlimited tonnage license. This guidance applies without regard to whether the ATB was engaged in towing astern or pushing ahead at the time of service

46 CFR Part 11.211(d) where “dual-mode ITB” means “ATB”, that is the CFR reference you’re looking for.

[QUOTE=DirtyRodriguez;163651]I’ve heard a rumor that ATB’s tonnage is now calculated with their respective barges, giving Mariners unlimited sea time. I’ve searched the forums and am to lazy to look it up in the cfr’s. Anyone confirm this?[/QUOTE]

The only chnage to the applicable reg was to add ATB. It used to just say ITB. Other than that. nothing has changed, the provision has been applied to ATBs for a long time.

[QUOTE=jdcavo;163663]The only chnage to the applicable reg was to add ATB. It used to just say ITB. Other than that. nothing has changed, the provision has been applied to ATBs for a long time.[/QUOTE]

Regarding combined tug and barge time, if someone has 360 days at 2/1 equaling 180 days of combined tug and barge tonnage time over 5000 grt, has over 360 days sailing as master on vessels over 100 tons, has 180 days on a 1400 grt vessel, but has no time on self-propelled vessels over 1600, what type of tonnage limitation should the expect to come with Third Mate “unlimited”? 2000? 3000? 5000?

[QUOTE=tugsailor;163724]Regarding combined tug and barge time, if someone has 360 days at 2/1 equaling 180 days of combined tug and barge tonnage time over 5000 grt, has over 360 days sailing as master on vessels over 100 tons, has 180 days on a 1400 grt vessel, but has no time on self-propelled vessels over 1600, what type of tonnage limitation should the expect to come with Third Mate “unlimited”? 2000? 3000? 5000?[/QUOTE]

See 46 CFR 11.402

[QUOTE=jdcavo;163751]See 46 CFR 11.402[/QUOTE]

According to that CFR, a mariner only needs half of his qualifying time on vessels over 1600 tons to qualify for Third Mate.

A mariner can use combined tug and barge tonnage for half of his required seatime toward an unlimited license.

Therefore, according to 46 CFR 11.402, a mariner that has half his seatime toward Third Mate on tug barge combinations over 1600 grit should receive an unlimited Third Mate without any tonnage limitation.

Negative ghostrider. According to 46 CFR Part 11.211(d) the combined tug and barge time only applies to half of that time over 1600 tons. I actually specifically says that the rest must be acquired on conventional self-propelled vessels. They really went out of their way to close that loophole. Not very just in my estimation, but there it is. I have however heard of mariners upgrading their unlimited licenses based solely on ATB time but I think that has a lot to do with which evaluator you get, how closely they’ve read the CFR’s and finally whether or not they’ve had their coffee and doughnut that morning…

[QUOTE=PaddyWest2012;163762]Negative ghostrider. According to 46 CFR Part 11.211(d) the combined tug and barge time only applies to half of that time over 1600 tons. I actually specifically says that the rest must be acquired on conventional self-propelled vessels. They really went out of their way to close that loophole. Not very just in my estimation, but there it is. I have however heard of mariners upgrading their unlimited licenses based solely on ATB time but I think that has a lot to do with which evaluator you get, how closely they’ve read the CFR’s and finally whether or not they’ve had their coffee and doughnut that morning…[/QUOTE]

What the CFRs (or any law) may say in black and white is often very different from what a government agency may interperate it to mean, and how a regulation may be applied in practice.

That is why I asked the question in the first place.

I’m on your side, I fully believe that 1600-ton licenses should be able to more easily upgrade to 3/M U/L but there really doesn’t seem to be any room for agency interpretation on this one. The law is clear.

My question is how many hours as first class pilot are needed to count as a day? If I sail on my pilotage endorsement for 2 hours does it count as a day, or not?

[QUOTE=PaddyWest2012;163762]…They really went out of their way to close that loophole.[/QUOTE]

How is counting sea service on an ATB as 10,000 GRT (even if only for half of the total required) but only requiring it to be manned as if it were 199 GRT closing a “loophole”? Sounds more like opening one.

It was my understanding that the loophole was once wider than it is now by not making mention of “conventional vessels”, which the present form does. That’s what I meant by closing.

I’d still like to know, if a tugboat guy has:

  1. Master 1600 and master of towing

  2. 1000 days sailing as master on tugs over 100 GRT (mostly 199)

  3. Over 360 days sailing as master of documented tug and barge combination tonnage over 5000 GRT, which is credited 2/1, totaling over 180 days toward Third Mate

  4. But no time on conventional vessels over 1600

What if any tonnage limitation should he expect to receive on Third Mate “Unlimited” ? ? ?

Wow! ,I’m glad I’m in the ER, Sounds way too confusing

 Third Mate 2000 Gross Tons Limitation.

Calculations for tonnage limitation are on page 2:

http://www.uscg.mil/nmc/checklists/pdfs/mcp_fm_nmc5_05_web.pdf?list1=%2Fnmc%2Fchecklists%2Fpdfs%2Fmcp_fm_nmc5_05_web.pdf&B1=GO!

None of that answers the question.

It’s clear enough to that if a guy holds master 1600 / 3000 and master of towing, and has 360 days sailing as master on a vessel over 100 tons, then he qualifies for Third Mate unlimited with a 2000 ton limitation.

If he has 180 days of sea time on vessels over 1600 tons, he qualifies for Third Mate with no tonnage limitation.

So the issues is only about the 180 days over 1600.

However, if he also has 360 days (credited 2/1 as 180 days) on a 5000 ton tug barge combination, then he has the 180 days required on vessels over 1600 for Third Mate without a tonnage limit.

That 180 days must be on vessels over 1600, but if he can use combined tug and barge time for half of that 180 days, he should only need 90 more days on self propelled vessels over 1600 tons.

Over course common sense would suggest that if he has the 360 days sailing as master on a vessel over 100 tons and qualifies for Third Mate with a 2000 ton limit, and In addition he has 360 days more on tug barge combinations over 5000 tons, that he should be entitled to more than a 2000 ton limit.

A 2000 ton limit would make the license worthless because there are practically no vessels between 1600 and 2000 to sail on.

A 5000 ton license would allow someone to sail because there are a few vessels between 1600 and 5000.

[QUOTE=tugsailor;163803]None of that answers the question.[/QUOTE]

How to find the answer