While a TOAR and a requirement for certain amount of tugboat experience are conceptually excellent ideas, the USCG’s implementation of it is so flawed that it accomplishes very little.
What’s the point of a one or two day TOAR course where virtually everyone passes doing deliberately easy tasks a few times, and most of the TOAR is pencil whipped BS? What is the point of long drawn out TOAR experience working on a tugwhere the captain is unwillingly and begrudgingly doing it?
What’s the point in a 60 day (12 hour days) tugboat seatime requirement that is too easy to fake, or even if completed in good faith, is most likely to be an experience that is too narrow in the type, geographic scope, and circumstances of the tugboat work OBSERVED.
All experiences are not created equal. While some experience working on deck of a tugboat has value, it’s really not preparation for the wheelhouse. Experience as an observer in the wheelhouse is much more valuable, especially if the captain is a willing and competent teacher, and actually lets the trainee handle the boat and barges. Experience as an observer where all one does is watch while nothing is explained, and there is no hands on opportunity to try it, is of little value to most people. There are a few talented and experienced people who could learn a lot from merely observing, but what about the other 90%?
Personally, I think TOAR and tugboat seatime requirements should probably be structured more like a combination of the NI’s DP training and Pilot training.
For example (assuming someone has solid seamanship, navigation, radar, chart plotter, AIS, ARPA, and watchkeeping skills):
Step 1: A thorough two week online course with a rigorous computer based proficiency exam.
Step 2: Two weeks of observer time for a particular type, style, and geographic location, of towing.
Step 3: A rigorous two week hands on simulator proficiency course for a particular type, style, and geographic location, of Towing. The failure rate in this course should be at least 50%. (If failed, return to Step 2).
Step 4: Two weeks of hands on tugboat training and practice for the particular type, style, and geographic location of towing. The failure rate should be at least 50%. (if failed, repeat Step 4 until required proficiency achieved.)
Step 5: Sail as as a tugboat “training mate” with hands on practice for 60 days.
Step 6: One week capstone simulator, and hands on, tugboat training course for the particular type, style, and geographic location of towing. The failure rate should be about 25%. I f passed, Receive USCG Mate of Towing with no further testing for a particular type, style, and geographic area of towing.
Step 7: 180 days of sailing as licensed Mate, to be eligible for accelerated training for different types, styles, and geographic locations.
Types of towing: on the wire, ATB, Pushing ahead, on the hip, and combinations.
Geographic Areas/Local Styles: Oceans, East, Gulf, and West Coasts, ICW, Lakes, Bays and Sounds, Harbors, Harbors with Rivers, Lower Miss; Upper Miss; Columbia River, West Coast Bar Crossings, etc. Major Ports: NY, Chesapeake, Florida, Houston, LA/LB, SF Bay, Seattle, etc. Obviously, there could be some combination courses given in certain places.