I’ve recently applied with my local REC for FCP. It has definitely been a learning experience to say the least. Here are the facts:
-I hold a 1600 master oceans w/master of towing
-I am a career tugboater (15 years) with no time on vessels over 1600 grt
-I meet all sea service requirements of FCP
-I did not go to a maritime college, or ever hold any unlimited license
-I recently documented 15 observer trips on a vessel over 1600 grt
-I am approved for FCP limited to vessels UNDER 1600 grt
My question pertains to upgrading from my Limited FCP to Unlimited. I have read the USCG issued FCP letter several times and need clarification please. It states:
B.1.b - If an applicant does not have sufficient experience (18 months) on vessels over 1600 gross tons, the license or endorsement will be issued for a limited tonnage until the applicant completes additional round trips (20 on vessels over 1600 gross tons for initial endorsement and 15 round trips on vessels over 1600 gross tons for each additional route).
I understand the above stating I’ve already completed 15 round trips, I will just need to do 5 more (totaling 20) trips to upgrade from limited to unlimited on this original route. Other local mariners that have completed their routes agree they only did 5 additional trips to upgrade. The Local REC is suggesting a different approach, which I will do 20 more trips (totaling 35). The information listed in CFR’s all point back the local OCMI. I am not pointing fingers at who’s wrong or right, but looking for a clear understanding of what I’m up against from more than one perspective.
Any help or experience is greatly appreciated. Thank you in advance for your time.
Was the decision from the NMC, or it’s subordinate field office, the REC? Decisions on applications for endorsements are to be made by NMC. RECs should not be evaluating and making decisions on applications.
Which is the case on all licenses except local pilotage. The NMC recognizes local REC’s are more familiar with their own region. So in my case, the REC evaluates my pilotage (trips, tonnage, route) and tells the NMC what I qualify for. The NMC essentially prints whatever the REC tells them too. I’m sure there is more to it than that, however that’s how it was explained to me by my REC.
This is why I asked the original question. The requirements are “clearish” when you read the document above. I am hoping there is something or someone else that can shed a light on it from experience. There probably wont be anyone in my region that will have any insight on this. I’m interested in what other regions are doing. I cant be the only 1600 master getting a FCP route that hasn’t been on big ships or an academy.
What makes me so different than most is I am a hawspiper on tugs. I do not have an unlimited license… If I did then the license would be issued without restrictions on the first shot. In my case I have to do 15 trips to get a limited license then potentially 5-20 more round trips to upgrade unlimited on each route. In my region there are a lot of routes.
Ultimately I want to get my original limited route license on said route, then do 5 more trips to remove the limitation making it AGT. Doing 20 more trips will be very difficult.
It’s the case on all applications. The OCMI will advise, but it has to be the NMC’s decision. The OCMI has no authority over applications (any application) and the REC is not in the OCMI chain of command. It has to be a decision of the NMC. This distinction will be very critical if you elect to appeal, see 46 CFR 1.03-20 and 46 CFR 1.03-40.
Are you using combined tug and barge tonnage for your trips?
Does Seattle still credit up to four (4) trips per day? If so, it only takes 5 days to get 20 trips on most ferry routes.
My thought would be that it’s easier and faster to do the 20 extra trips first, and then get at least one unlimited tonnage pilotage route endorsement on your license. Once you have one or two unlimited pilotage routes, the OCMI is more likely to give you unlimited tonnage on additional nearby routes.
This is yet another example of the USCG’s absurd fetish for tonnage and nonsensical discrimination against tug and barge experience. The USCG puts more value on sweeping and mopping and chipping and painting on a 1600 ton vessel than it does on commanding, navigating, and handling a tug and barges. Makes no sense, except to academy grads.
Unfortunately there is no value in doing 20 trips first. Only 15 trips are used for the limited license to be issued. Only then I’m allowed to do 20 more trips to upgrade.
The only break from the REC on trips will be once I hold a FCP unlimited on one route, it will only take 12 trips to start on a limited license, then 15 to upgrade on any other route. I hope there is some wiggle room for relief from doing so many trips after I have a few knocked out but I’m not counting on it.
I have logged tug and barge trips. However we dont move barges that much anymore (which is nice) so it doesn’t add up to much. The ferries are my only sure way of qualifying for tonnage on those routes.
What I find so crazy is only 50% of my tug and barge time can be credited towards a master AGT inland. At that rate if any point in my whole career I was an OS on a vessel over 1600 for 180 days, I wouldnt have this problem. Things would be so much easier. Instead my first year I worked 289 days earning my position on a tug, chipping paint at 0200 in flood lights, or polishing the boat to museum quality. The work load is huge being a deckhand in the towing industry. The work has only changed a little, but the days im gone has went down alot.
I hold nothing against anyone who’s every been in an academy. Right now I wish I had their license! I’m still proud of being a hawspiper, but it’s fair to say that gets very little credit or respect these days. I will leave it at that and keep the rest to myself. I bet it wouldnt take to much time to find a forum topic on this stuff.
I’m still hoping there is something out there that can simplify these rules.
This is certainly an unfair pain in the ass, but it’s not insurmountable. Doing an extra 20 trips on a short run only takes 5 days to get your first unlimited Route. Then upgrading the next route will only take 3-1/2 days.
If you are trying to transition to the ferries, I would think that the important thing would be to have a few pilotage routes in hand, even if you need more trips to lift the tonnage. The ferries will make you park cars and clean toilets for six months, which will give you a chance to acquire extra trips to lift the tonnage.
You can get Master Inland AGT with a 2000 ton restriction just by using your tug seatime and taking a very easy exam.
Is there any way you can document combined tug and barge seatime from many years ago (all those trips to Alaska)? That will at least bump up the tonnage restriction on the Master Inland.
You might want to talk to Crawford’s and PMI. They are probably very knowledgeable about the situation you face.
No ****. The OCMI sets the trips. I didn’t say otherwise, and cited the regulation that says that. I was addressing the recourse if the poster disagrees with the trip requirement related by the REC.
Yes, the OCMI sets the trip numbers. However, it’s the NMC that makes the deciuson whether or not a given mariner gets the endorsement. If you can’t figure out the significance of who decides the appeal of a denial of an application for the pilotage, especially of if the statedf requirements exceed the range specified in the CFR, there’s no point in explaining it to you.
Not necessarily. At least some pilotage districts (if not most) accept applicants who meet the minimum qualifications that typically do not require pilotage for the district they tested for. A lot of folks just roam around testing for pilot organizations all over until they get in with one of them.
The local OCMI can institute separate and more stringent requirements to be met.
For one area I know intimate details:
Applicants who present trips on vessels of more than 1600 tons, are granted Unlimited FCP.
Applicants who present trips on tug/barge combinations over 1600 tons will be issued a restriction to Tug/Barge FCP on specific route.
Applicants who submit trips on vessels less than 1600 tons are issued a limited pilotage based upon route, and must be employed at the specific company being used to gain trips on the route. ((But, if you curry favor at REC you can conveniently be ‘overlooked’ in the writing of the restriction. )) ( I know this from @#$%^& experience)
And in another AOR:
Applicants must have all trips over this route signed by members of the XXX Pilot association. (good luck getting those signatures!)
So, to OP, find out what the local OCMI has for restrictions on issuing pilotage in your area.
Dayummmm!!! You nailed it!!! Have got many of these unlimited experienced (blue water) guys come over to tugs over the years and have throw them in the seat in NY Harbor and its a live comedy show. But, its the height of hypocrisy to discredit a tug/barge guy’s/gal’s lacking sufficient tonnage.
I did hear the USCG started recognizing and accepting the combined tug/barge tonnage a few years back. I’m not a CFR nazi, so is that correct Mr. Cavo?