[QUOTE=PMC;31697]What I know or think I know about manning level requirements only comes from surfing the internet. I did find an application form where the boat makes proposals for manning levels to the MCA. Here is the form: http://www.mcga.gov.uk/c4mca/safemanning.pdf.
I am not attacking the MCA here. I question why the Coast Guard is ratcheting up the 200-500 ton requirements when other flag state agencies already are, in my opinion, already less demanding that the US when it comes to the 200-500 ton licensing requirements.[/QUOTE]
Go ahead and attack, the MCA and its yacht licensing scheme is a legitimate target. It needs a spotlight on it. That application for a manning document is a standard form for the MCA to determine where to start. Just like all the other certificates that make up the vessel’s documentation, you have to request surveys and pay for them. The existence of a form to supply the basic information does not mean that the limitations of the certificate are negotiable. Safe manning certificates are called “minimum” for a reason, if you want to be amazed, look at one for a very large cruise ship.
One thing to keep in mind is that MCA is not a flag state. Relatively few yachts are registered in the UK itself, most are flagged with a “Red Ensign Group” country and while most of those maritime administrations simple cut and paste UK MCA guidelines, they each own their rule books. And for what it’s worth, even the MCA doesn’t accept a yacht license for domestic commercial service. A yacht license is a dead end ticket, it does not lead to higher licensing.
Yachties like to claim they have a “commercially endorsed” license, that is a bit of a play on words since all that means is that the ticket they bought from a storefront yacht license school tacked on the words “commercial yacht” to the ticket they sold with the blessing of the MCA. There is still a wide gulf between a real license and a yacht limited license. But, scary enough, as yachts continue to get larger the MCA is considering a means to allow yachties to crossover to a real license. They don’t want to kill the golden goose of yacht licensing.
As far as comparing yacht licenses to the US system of lower level licensing, it is not worth the trouble as there really is no comparison. US lower level licenses are stepping stones to an unlimited license, each level is a commercial certificate that allows legitimate commercial authority. It is an apples to oranges comparison. Much of the confusion in this area between the yacht licenses and how we look at US lower level licenses is because the yacht schools (who actually issue licenses on their own forms) love to use the same terminology as real licenses, and the holders of those cereal box certificates will never use the term “yacht limited” in any circumstance.
The question that should be asked of the IMO and member port states is how they can allow a commercial vessel carrying passengers for hire (these are not bare-boat charters) on an international voyage to operate in their waters with officers and crew who do not meet STCW requirements for training and certifications that state requires of the crew of a ferry or small passenger vessel performing an identical voyage.
Foreign flag commercial yachts do not charter in US waters. There are a few loopholes that allow them (openly or otherwise) to pickup or dropoff “guests” in the US Virgin Islands but when you see a foreign flag yacht in the US, it is registered private. It is very easy to change from commercial to private registration and it is a common and legitimate practice that some yachts do several times each year in popular yacht destinations in the US. It keeps Florida boatyards full of business. It also keeps south Florida full of blue eyed blonde illegal aliens walking the docks looking for yacht jobs but that is another issue altogether.