I am presently sailing as a mate of tow on a 99 grt tug. I will quickly have the 90 day recency to upgrade to master 500 grt. According to the checklists, this shouldn’t be an issue with a 99 grt tug.
Buuut, I’m curious about upgrading to mate (eventually master) 1600 grt. With the tug being 99 grt is this a possibility? I’ve looked up the combined tug and barge time as outlined in the CFRs. As I understand the regulation, it’s credited on a 2 for 1 basis. We tow the same barge on a very routine run which is well documented in the logs and so on.
Previous threads were helpful in finding the CFRs, but seem dated, and mostly explained that this is going to be a hassle.
Has anyone had recent experience using this CFR to upgrade? Issues? How does the 2 watch 12 hour day work in conjunction with the combined tug and barge sea time calculation? Suggestions to make it easier for evaluators? Can anyone recommend a license consultant who is well versed with the towing world?
The Evaluators are incompetent and don’t know what they are doing.
My experience a few years ago was an 11 month ordeal that included a denial of any combined tug and barge seatime, and then an ultimately successful request for reconsideration that credited my combined tug and barge seatime.
You should get 3/4 of a day for a day seatime credit.
You should probably put your application packet in a binder with a table contents up and an appendix that includes you seatime letters, certificates of documentation for the tug and the barge, COIs for the tug and barge, and copies of the CFRs regarding combined tug and barge tonnage seatime credit.
Your seatime letters should be very well written and include the barge and tug tonnages, official numbers, names, etc, and in all caps state the COMBINED TUG & BARGE GRT pursuant to CFR xxx.yyy.
Put the same language and CFR cites in your application.
I think you should use a license consultant. You might try Chuck Kaksuka at Sea K’s Licensing in the suburbs of Toledo.
I have not had any recent experience with NMC, except plain vanilla renewals.
Thanks for the quick reply, as well as all of the suggestions. If I remember correctly you outlined that ordeal in one of the previous threads.
I think I’m going to apply for the 500 grt master separately from the 1600 ton mate. I don’t want to mess around with split issuances, or reconsiderations of a portion of the application.
I’ll reach out to the consultant you suggested as well. I’d like to avoid an 11 month paperwork ordeal with NMC. That sounds like a special circle of hell. Spending the extra money will be worth it.
Funny how that 1 grt makes all the difference.
Honestly, I’d recommend reviewing your career goals and go from there. If you’re eligible for 1600, it definitely makes sense considering the exams are the same for 500/1600. Buuuuut, if that 1 grt is going to be a hassle and likely cause delays for no net benefit, what’s the point?
If it were me, I’d consider taking the 500 for now and upgrade to 1600 later after gathering sea time on a larger tug.
I have found that NMC gets confused very easily if you ask for several, especially different types of endorsements, at once.
However, Master 500 and Mate 1600 based upon the same seatime fit together quite well on the same application. I would ask for both of those at the same time.
That can be used for part of the requirement for time over 100 GRT, but not all. At least one year of the total for Master 1,600 has to be as Mate or Master on vessels over 100 GRT. See 46 CFR 11.412(a).
Awhile ago I had two guys, a third mate and an AB, quit on a 99 GRT tug because they had been told by someone that they could not get combined tug and barge tonnage seatime credit.
According to them, if the tug is under 100 GRT, there is no combined tonnage seatime credit.
Apply for master 500, don’t waste your time with mate 1600. Sailing as mate on towing vessels now you can sit for the limited three module exam for 500 master near coastal. Or sit for 6 or 7 exams for mate 1600? Then jump around the company work over on a bigger tonnage boat
That 99 GRT boat is going to make it hard to get a 1600 ton license.
Also, as previously asked, do you really need to get the 1600 mate’s license? You can upgrade from 500 master to 1600 master without having to retest with 360 days of seatime as master/mate of towing vessels (<100GRT🙁)
1600 mate is a different exam so you’re looking at like 11 modules to get both. I actually did that several years back. The reason I did was the 1600 mates license made it easier to get the OICNW endorsement quickly at that time, when they were grandfathering people in with “gap closing classes” etc.
If you don’t need OICNW though I would just get the 500 master, sail on that and try to get on boat bigger than 100 GRT for 360 days and then upgrade to 1600 master.
Thanks to everyone who has replied here and to those who sent private messages as well. A number of people independently recommended the consultant listed earlier in this thread, so I’ll be reaching out to him.
I forgot about the limited exam for sailing as mate of tow, thanks for the reminder, I’ll be looking into that.
I do hold an AB, but when I was decking Sub M wasn’t in play. My sea service letters from that time period just list “Deck” or “Deckhand”. I’ll have to look at the exact phrases in the CFRs and checklists to see if that time applies.
Speaking of CFRs: I’m referencing 46 CFR 11.211(e) for service on towing vessels and using the combined (aggregate tonnage) on a 2 for 1 basis. For clarity, I am on a wire boat. Someone in a PM mentioned that combined tug and barge time is only applicable for ATBs and ITBs, which I don’t think is correct. That sea service reg is outlined in 46 CFR 11.211(d). Why would they make a distinction between towing vessels and ATB/ITBs if the service on a wire boat (towing) wasn’t creditable?
As for reevaluating career goals, I am definitely testing for the 500 grt master NC. Once I speak with that consultant I’ll figure out the 1600 ton mate. It may make more sense to stay on the Master track as mentioned by a number of posters.
Thanks to everyone for the information, discussion, and suggestions on how to proceed.
Test for master 500 with what you have now get MF to write the sea letter with the combined time , then use with when applying to upgrade to 1600 master a year later. This is your best route. And when you write you work on a 99GRT wire boat everyone knows where you work lol. Then only upside to getting a 1600 mate is you can go to 3rd mate unlimited without testing. But in your case it would never be unlimited prolly 2000grt. Stick with the masters route
That CFR (46 CFR 11.211) is very ambiguous. It says sea service on ATB/ITB units is creditable to ANY deck endorsement, but sea service on a conventional tug and barge is creditable on a 2 for 1 basis for up to 50% of the remaining sea time for an unlimited license, the remaining time must be on a vessel <1600GRT. Doesn’t say anything about using that time for a limited deck license. So that leaves it open to interpretation by the evaluator which can go either way it seems.
It is a commonly held misnomer that combined tug and barge tonnage is not applicable to tugs that tow on the wire. That is not true.
The combined tug and barge tonnage seatime that I eventually got credit for after a request for reconsideration was mostly towing on the wire with some pushing ahead time.