IMO the Coast Guard has made another big licensing mistake

I’ll get around to the mistakes in a while. But first a little background - a little bit at a time. I will continue to provide additional information in thread updates:

My first license - 100-ton master with sail and towing endorsement

I came up through the hawsepipe. Nine years ago, after 20+ years in the corporate world I quit my job and started working on sail training vessels. At that time I had about 450 days of sea time as a volunteer on sail training vessel less than 100-tons. And another 200 days of the time I could document on my own boat I had been self-studying on a casual basis for my 100-ton course for more than a year. I never took the Coast Guard exam thinking there was still an endless amount of material that could be on the exam. On the advice of a friend. I took a two-week 100-ton class taught by a retired Coast Guard chief warrant officer. It was a great course.

The instructor had been in the Coast Guard for 27 years and had a 500-ton license. He was enthusiastic and knew his stuff. Many of my classmates did not own their own boat Many did not know how to tie a bowline. Most did not know anything about line handling. Virtually none of them had worked on a boat. I was the only person in my class who had sailed on a sail training vessel.

So where did they get their sea time? And what was the quality of that sea time? I really don’t know. But I do remember that some of them had best friends or relatives that had sports-fishing boats that they were looking to work on. Another worked in the office of a company that did harbor tours during the day and booze cruises at night. I think there were three out of 17 students who were retaking the class for a nominal additional fee.

For an additional $100 I took an additional afternoon class to get a sail endorsement. The instructor looked at us at the beginning of the sailing lecture and said “you all have at least 360 days on a sailboat and I don’t sail”. I don’t remember what was on the exam but I do remember that it was 10 multiple-choice test questions; and, that anyone who had ever taken a dinghy sailing class would have passed with flying colors.

After two weeks I walked out of class with a certificate good for a 100-ton near-coastal captain license on power and auxiliary sail. And a towing endorsement that required zero-experience. There was not even a requirement to have seen a boat being towed. Or seen a towboat at the dock! I think that also has a 10-question test on towing also.

But I was licensed by the Coast Guard to take 30 or 40 kids offshore in a 99+ ton vessel. There was a restriction on miles offshore. But it did not matter if I had never seen fog, or high winds, or high seas. Or even if I had ever been underway in the dark. At this point the largest vessel I had significant “ship-handling” experience on was a 42-foot sailboat I had rented for a weekend.

I knew my license was just a piece of paper. Kind of like have a permit to carry a loaded weapon. I knew my education process was just beginning. I wondered about my classmates with new captain licenses who never worked on a boat, owned a boat or sailed…

More in a couple hours…

After a delivery on mega-yacht I learned that life onboard was pretty good. I learned that the RYA offered a 200-ton yachtmaster licensing course that included one week of class time with an emphasis on tides and currents and a week of ship-handling – approximated 55 hours on the water followed by a 10-hour on-the-water ship-handling exam with an examiner. Test was on a twin-screw 48-foot vessel.

It was a great course. I learned a lot. On the flip-side the RYA course limited one to private vessels and only required 55 days of sea time to get a masters license. That’s right – 55 days – no typo.

For the first time, I felt that my 100-ton license actually was worth something. I had crossed the Atlantic a couple of times. Sailed from the west coast to Panama and Hawaii. I had some good classroom experience with the basic principles of ship-handling. I knew the rules inside-out and I could find my way around the CFRs. And I could work with foreign chart current and tidal information.

Within the two years that followed I had taken GMDSS, radar and ARPA for the information content. And I had upgraded my license to 200-tons. I had about a 1000 days of sea time,

I was off to foreign flagged mega-yachts for a couple years where you could make some pretty good money and visit some interesting places. Also the mega-yachts had every type of bridge equipment imaginable. The manning requirements only required a licensed captain and an “adequate” crew. Other than the captain the only course required was STCW. And no OICNW licenses - amazing!

But, back home, the Coast Guard did not require STCW – also amazing!

More to follow…

I have a feeling c.captain is sharpening his pointy stick somewhere.

I’m sitting back and relaxing. This is going to get good!!

It is too bad this is posting backwards. It would be nice if it were in chronological order.

Obviously not quite enough …

I was off to foreign flagged mega-yachts … The manning requirements only required a licensed captain and an “adequate” crew. Other than the captain the only course required was STCW. And no OICNW licenses - amazing!

But, back home, the Coast Guard did not require STCW – also amazing!

Yes, simply amazing … simply amazing that anyone could spend a 'couple of years" on foreign flag “mega-yachts” and still post nonsense like that. What were you, a third stewardess?

For those who are interested; many, if not most, of the world’s “mega-yacht” fleet is flagged in the Cayman Islands. Linked here is the Cayman Islands safe manning policy document.

There have been a few changes since this was issued, the most important is that they now require a commercial registered yacht with a safe manning certificate to follow the manning requirements even when operating privately. That isn’t as weird as it first sounds, yachts often shift between commercial and private certificates, particularly when entering US waters where commercial operations are are essentialy prohibited. A yacht that was chartering in the Caribbean for example under a commercial registration will change to private before going to Fort Lauderdale for refit work prior to going to the Med for the Summer season.

[QUOTE=KennyW1983;70437]I have a feeling c.captain is sharpening his pointy stick somewhere.[/QUOTE]

Naw…I want to hear the rest of this tale…I hope our poster returns to tell us it although I wish he’s tell it to us in a less rambling fashion.

I am also going to say that I do agree with his intent on what he is trying to convey…the system to certify persons as “competent” mariners has diluted steadily over 30 years. A 100ton master’s license is thought of many as a “little ticket” but think how many T boats are certified to carry 200 people! That is a lot of responsibility for a master even if the vessel itself might not be worth $200k. I would want the person in command to have skills, knowledge and experience commensurate to that level of responsibility. The way 100ton licenses are tossed out by the USCG just the holding one is no proof of that. Many yacht owners manage to get them without one day of commercial vessel operations experience!

The good news is that there are many 100ton mariners out there who do have the skills, knowledge and experience to safely operate their vessels and one company I am very familiar with who operates small passenger vessels on the west coast has high standards for their masters to meet. They pay better than average (yet still quite a ways below just about anyone else in the NW such as towing) so can demand more and get it. In all reality, there is no big fundamental difference in the job done by lower tonnage masters and higher. The USCG should make the process for these people to become certified not a giveaway such as what PMC describes.

From the TRITON yachting mag:

Earning your captain’s license should be hard

Attendees of The Triton’s May Bridge luncheon were, from left, Darren Nightingale, Paul Canavan, Rustin Nightingale, Gordon Ward, Veronica Hast, Brian Conner and Norm Treu.

By Dorie Cox

May 28, 2010

Being a captain on a megayacht is tough, but actually getting the license can prove even tougher. It takes instructional courses, paperwork, time at sea, time away from work and money.

“My guess is, it costs at least $25,000 to get a license,” a captain said at this month’s Triton From the Bridge captains luncheon.

Captains were invited to discuss obtaining and maintaining licenses and certifications and the future of licensing in the yachting industry. The captains in attendance have varying licenses and levels. Included were MCA, USCG and Royal Yachting Association (RYA) tickets varying in size with experience ranging from several years to several decades in the industry. Each captain had a different course in their licensing story.

“I took the 200-ton, then straight to 1600-ton,” a captain said.

“I started with a 500 MCA, so I’m not affected by coast guard changes,” another said.

“I’m on my seventh renewal,” said a third.

As always, individual comments are not attributed to any one person in particular so as to encourage frank and open discussion. The attending captains are identified in the accompanying photograph.

Problems with licensing

Licensing is an ongoing issue for crew as they continually navigate official Web sites, communicate with bureaucracies and sift through codes of federal regulations and notices to mariners. They monitor their peers for news and watch for suggested classes trying to stay ahead, or at the least on track.

“I have really pushed it to get my license. I have had to fly to Antibes, England, wherever the courses were, during my holidays, to get it done,” a captain said.

Sometimes captains have quit a job to take courses.

“But it paid off to work so hard to get the license, some guys that started with me are still chasing their lower license because they didn’t push it,” he said.

It’s hard to avoid having a ticket and most wouldn’t take the risk of not being licensed. Insurance companies often control who is allowed to work onboard and most new hires have to be approved by underwriters.

“I’ve seen crew denied by the insurance company,” a captain said.

Another issue is sea time. It is counted differently between USCG and MCA and it can take more time at sea for Americans to get their license compared to time required for MCA license.

“Has the USCG ever verified anyone’s sea time?” a captain asked and no one knew of the coast guard calling to verify their sea time.

“I did both U.S. and MCA because it was easy to do,” said a captain who explained how MCA will grant a certificate of equivalent competency (CEC) for a U.S. license holder, but the USCG will not grant an equivalent license for the MCA. And only U.S. citizens can get USCG licenses.

“But MCA is still the big dog in the fight and they’re barking the loudest, they’ll make the changes,” a captain said.

“I’m not a fan of MCA, but it has brought rules and talent to the industry.”

“A 10-day course pretty much guarantees you a license,” another said.

“But this is about so much more than courses,” said a captain describing how someone can have a license to drive without much time at the wheel. Several captains agreed that it can be a potentially dangerous situation where a crew has been on the same boat since being a deckhand and has worked up with sea time to get a license, but may not be ready to handle emergencies onboard.

“And that creates a situation where they’re not trained to handle anything that happens outside the box of what they learned. It takes experience to handle situations in real life as opposed to a course,” said another.

“It should take 15 years to get on the big yachts,” a captain said.

“It costs a lot but I tell a guy that is starting to itch to change and move up to get experience on other boats. I’m a stepping stone and I know that, but I do expect loyalty until the day you leave. I expect 100 percent while you are with me and I am proud of my crew that have moved up.”

“How can you learn anything if you don’t go anywhere?” another captain asked.

What works with licensing

Several captains agreed there are a few areas where the industry is doing a good job. One such direction is that insurance companies are looking more at experience instead of just the level of license.

“Underwriters really have the control in this and they are looking at CVs now,” a captain said. “The resume really is the most important. They have to work up through the ranks, that’s why you’re called professionals.”

“I heard insurance companies are making people go through the simulator,” said another about how the insurance companies are actually guiding the industry.

Everyone at the table was happy with their current license level with one planning to do his 3,000-ton orals after preparatory courses.

“The MCA handles sea time much better with the seaman’s book and it is important to tell crew to that. They have to record their sea time from the beginning,” a captain said.

A full medical is required for MCA and that’s a good thing, said several captains. You have to have it every two years but they can put stipulations on it, like require a medical every year if there are issues. They will flag you for diabetes, high cholesterol, heart conditions, high blood pressure and more.

“In U.S. licensing you have a brief medical, the basics, like your heart and are you color blind, it’snot like the ENG1,” a captain said, in reference to the Acceptable Medical Fitness Certificates of MCA.

“I have to really get in great shape before that one,” another said.

Future of licensing

Yachting is a worldwide industry and yacht captains see with a global focus, so discussion grew to licensing in different countries.

“I think Australia is starting to coordinate with some of the international licenses. Now, there is an Australian master license, but you still have to do MCA courses,” a captain said.

“I heard Belize may get a new 5,000 ton license,” another said.

“I would imagine the MCA has pending changes, too,” said a third.

“It’s hard if I go home because I would have to change all my tickets, it’s not like the U.S. where you document time, i have to go back to school. But i think they are trying to close the loopholes,” a captain said.

Pending changes in Florida sales tax laws could limit the tax on yachts, allowing more vessels to register in the state. This conversation prompted a captain to say, “The Florida sales tax cap will cause people to want more American licenses because there will be more U.S. flagged yachts, but right now the big boats are all flagged offshore.”

Requirements are scheduled to change for both the U.S. Coast Guard licensing and Standards of Training, Certification and Watchkeeping (STCW) with modifications that could affect many mariners. If the USCG expected changes are implemented, they will not issue new 100, 200 or 500-ton licenses and will make the 1600-ton the lowest level master/mate licenses for oceans and foreign going routes. Qualifying time for 1600 and 3000-ton licenses would be 75GRT.

“The 500-ton test is the same as the 1600 test, anyway.”

“But the maritime industry is more than yachts, and the changes will seriously affect boats like tugs, where the guys will not have sea time for 1600-ton,” a captain said.

“The idea with the changes is to stop the problem of the guy that was a mate for two years then moved up to get a license without really being in charge of the yacht.”

Each of the captains expressed pride in their career choice.

“This is such a great career for the right people,” a captain said, “and you can pick out the new ones that are in it for the right reasons like us.”

The captains agreed they have worked hard to get where they are and all try to keep informed on their education and paperwork.

“And we know being qualified on paper is so different from being qualified for life,” a captain said, "hopefully, the proposed changes will fix that."
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Dorie Cox
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To respond to Steamer’s witty post, it was a Cayman-flagged Feadship. And the requirement of “adequate crew” came directly from the COI. The reality of the situation was that the manning requirement specifics was more likely to be determined by the insurance company than the flag state. Also, Steamer, there is no nonsense in this post. When I left the boat in 2006 after the boat sold, the only holdover was the deckhand who was promoted to first mate. The second mate and deckhand were also new. And, other than the captain, nobody had a license. I got off after the Atlantic crossing that December. The captain stood watch with the chief stew, I stood watch with the chef and the unlicensed second mate stood watch with the deckhand.

When I had been onboard the mega-yacht is was pretty professional Under the old owner, the captain required the two mates to have a 200 GT/500 ITC license with Radar, ARPA and GMDSS. These were the captain’s requirements - not the requirement of the COI. Perhaps the rules Cayman Island class rules have been tightened up since them. And maybe one now needs more than 55 days of sea time to be a 200-ton RYA captain.

Also I am posting this in chronological order.

Also, the purpose of this thread is to share a perspective (eventually) about licensing and the Coast Guard And to do that I need to provide my background to show where my perceptions come from. I make no judgement here about sail boats versus power boats, commercial versus private, MCA versus Coast Guard.

As far as boats I have been on, I picked each boat because I thought it was a good learning opportunity.

More later.

What I meant is it is hard to read chopped up, with the last part first. even a paragraph at a time is tough.

[QUOTE=PMC;70449]Also, the purpose of this thread is to share a perspective (eventually) about licensing and the Coast Guard And to do that I need to provide my background to show where my perceptions come from. I make no judgement here about sail boats versus power boats, commercial versus private, MCA versus Coast Guard.

More later.[/QUOTE]

Eventually! Just quit with the life narrative and cut to the chase! Say what you intend to say in one more post…

don’t make me use my pointy stick…please

.

Okay, I"ll continue. To summarize, up to this point, I got my 100-ton, 200-ton and AB through the regional offices. Then I decided to go the commercial route. I go the 1600-ton mate route. And of course my file is transferred to West Virginia where I have misadventure after misadventure with the NMC. First with the 1600-ton mate, then 1600-ton master and lastly third-mate unlimited.

I doubt there a lot of mariners who went down to the sea have come from West Virginia. The biggest body of water is a 2700-acre man made lake. The closest West Marine store is in Pittsburgh - 133 miles from the West Virginia state line. And these people have to understand every part of the industry as is relates to credentialing? How could there be anything other than confusion.

And now to make c.captain happy, I will start to tie things together.

For many years, the philosophy of the pre-NMC Coast Guard was that the US commercial mariners would pick-up their education while underway. Meanwhile the European licenses put more of an emphasis on classroom learning. STCW courses, I was told , was an attempt to level the field with the European classroom requirements.

My first license was an example the old philosophy. I had a 100-ton license after a 720 days of sea-time. None of that time had to be at the helm. None of that time had to be as mate. But there was an understanding that people were not going to be put into a position of responsibility until they were ready. And that would be up to the captain and the company that owned the vessel. I eventually became mate and later captain. The piece of paper was only the beginning of the process.

I have no idea what the Coast Guard’s philosophy is now. What were people in Washington thinking when they decided that is would be a good idea to centralize all of the NMC’s wisdom and oversight in Martinsburg, West Virginia?

Only today did I learn that many of those STCW courses I took were no longer required. I am not happy. And I wonder if foreign-flagged vessels will continue to accept my US license. For years they were told that the STCW coursework made the licenses the same. And now they will told that these classes are no longer required.

So I wonder: who is making these decisions. I thought we were getting rid of the small licenses? That is one reason I decided to go the large-ticket route. How about my TWIC card - my license was not going to remain valid if I did not fork-over $125 for a TWIC-card. Now I don’t need a TWIC card. I had take all of these STCW courses for my 1600-ton license. Now they are not required.

Whoever is making these decisions - I bet they can’t see ocean from their office window. Or for that matter a boat on a lake bigger than a ski-boat. I don’t fault the people in Martinsburg. I am sure they are working as diligently as they can. In particular I feel sorry for the people who have to deal with actual mariner. It must be like working in the lost luggage department at the airport.

One last thought for fellow hawsepipers: The Coast Guard pulled the databank questions for the exams. Now you don’t have to take the courses. But you still have to take the exams. What is going on?

[QUOTE=PMC;70472]One last thought for fellow hawsepipers: The Coast Guard pulled the databank questions for the exams. Now you don’t have to take the courses. But you still have to take the exams. What is going on?[/QUOTE]

I for one believed that the availability of having the questions before taking the test further reduced the level competency of license holders since all one needed to have was a good memory rather than any real knowledge. Sure, I had access to the books of questions before I tested the last time way too many years ago now to contemplate but I did not reply on only memorizing the questions either to pass. I also never went to a license mill where all they did was to teach the content of the exams.

I will say that the whole concept of the multiple choice license exam to have been one which does not truly test a person for anything of real value when it comes to competence. Who bloody cares if I know some obscure rule of the road about sailing vessels engaged in fishing meeting an RIATM vessel at anchor in a narrow channel or how many wires in a sample of old worn out rope can be broken before it is condemned? The correct answer should be to junk the whole rope if it has ANY broken wires! No exam really and truly can take the place of experience in whether a person is ready to be moved up to the next level of leadership at sea. How to qualify that experience tho in a manner that is equitable and fair for all? Evals by masters or chief engineers would be a potentially very flawed system which could be highly prejudicial or even become fraudulent (as already witnessed). Too much dock time is counted towards seatime yet discharges or company letters do not show anything other than the day on and day off and nature of the voyage. How does the FAA manage the licensing of commercial airliner pilots to keep incompetents out of the skies? They obviously have a system which works. Could the USCG use it as a model? I am sure they could but then again the USCG doesn’t give a SHIT about ensuring the competency of merchant mariners. Like I said once before here, as far as the USCG is concerned mariner licensing is in the basement behind the boiler which is no longer used in the room filled with used paint cans!

Regarding all the other changes the Coast Guard has made or continues to make to “their” licensing system, it is one playing field which I think each and every one of us plays on so nobody can say they are particularly disadvantaged by the inane rules of the game.

btw, thanks for the summation of your experience PMC altho it still seems kinda disjointed.

ps. the reason the NMC is in Martinsville, WV is because of Senator Richard Byrd who would have moved the entire federal government to WV if he hadn’t died first.

.

[QUOTE=PMC;70449]To respond to Steamer’s witty post, it was a Cayman-flagged Feadship. And the requirement of “adequate crew” came directly from the COI. The reality of the situation was that the manning requirement specifics was more likely to be determined by the insurance company than the flag state.[/QUOTE]

Caymans doesn’t issue a “COI” they issue a certificate of registration. You carefully avoid stating the tonnage, if it was a little boat - hardly a “megayacht” - and operated privately it would not have a Safe Manning Certificate and any old yahoo could operate it. Insurance companies don’t issue safe manning certificates, they will make a judgment with regard to the experience level of the master, even if that person holds the certificates required by Flag but they don’t trump Flag. Caymans don’t decide how many days it takes to get a yachting club certificate … do you know what RYA stands for? Have you ever actually read any of the certificates issued to a yacht? Have you ever read any of the flag state notices and regulations regarding licenses, manning, and training requirements?

What is the learning opportunity here? Are you claiming the USCG missed an opportunity to dilute the license system even further? The yachting license system is a dead-end, watered down version of a license that has absolutely zero value outside the yacht world. The MCA created that mess because at the time there were commercial vessels and there were yachts. Commercial vessels required real licenses and all that comes with obtaining one. Yachts were pleasure vessels manned according to whim. When yachts began to operate commercial charters it became obvious that manning by whim wasn’t good enough. The MCA saw a great marketing opportunity to replace the income they were losing as their merchant fleet declined. They took the standard Brit approach to such things and gave “licensing” responsibility to a yachting association, a club. The MCA wrote the rules and blessed the private for profit club as a license issuing company.

I suggest that anyone with an interest in working on yachts spend some time reading the huge amount of literature available online that describes the process of yacht licensing, its value (or otherwise) and how the system works. I don’t really want to come across as mean but the stuff posted by PMC is absolute nonsense. I wasn’t joking when I asked if he sailed as 3rd stewardess.

Obtaining an MCA license is criminally simple and doesn’t require much, if any, sea time. A self taught “engineer” can obtain the highest engineering license without ever having to spend a single day working on a vessel under the supervision of a senior engineer, or at sea for that matter. The wizards that system produces need to be seen to believe. Those who defend the MCA system always talk about the classes required for upgrades, what they don’t mention is that they are nearly all just week long cram courses provided by MCA franchised license mills. What passes for “sea time” can be obtained tied to the dock, which is good because most yachts don’t leave the dock very often and a year of real sea time could take 5 or 6 years if it meant “at sea.”

PMC, you might do the group a favor and just write a story about your yachtie experiences and stay away from trying to make it a message to the USCG or a description of yacht licensing. You should start with telling us exactly what “big licensing mistake” you believe the CG made.

And BTW, just for the record and your passage planning purposes, if you are at the NMC, the nearest West Marine store is about 54 miles away in Rockville, MD.

That’s it?? I thought this was going to be a productive thread. Come on all of you seasoned veterans out there…anymore comments on the current licensing structure???

I reread the op’s posts and was wondering what the point was… He took the tests passed them and steadily moved up in his profession. Whats the issue?

Sorry, I didn’t tie things together better. The issue if for people considering which a career at sea. People who start with a small license and work their way taking their on their own time and paying out of their own pocket. For example, folks who drive airboats in the Everglades or make $400 a month on a sail training boat who have to pay $125 for a TWIC card.

For years STCW schools have told prospective students should sign up quickly for the 500-ton or 1600-ton master license before the pending change that would double the number of STCW courses. Years rolled by with no change. And then a big change - a big reduction in required course work for the 500-ton and 1600-ton mate license.

How about the elimination of the ocean endorsement for licenses below 1600-tons? Wasn’t that suppose to happen in 2010? How about the tripling of required sea time for a 200-ton mate license?

I bet it is not a big deal for people whose company is paying for their courses, their room and board and continuing to pay their salary. I guarantee that’s not the case for everybody. And if you look over the past 10 years to see what the Coast Guard has said about upcoming STCW changes and measure it against actions you see delay after delay and revision after revision.

With the benefit of hindsight I would have gone a different route of the past five years to avoid things like not renewing my contract so I could week after week for six months for approval to test and then having to wait another four months to cycle into new position. For my next upgrade part of my file was lost. I learned about it after a couple of months.

But to the kid who wants start as a deckhand on a ocean-going 499-ton vessel with hopes of someday becoming a mate; and, who needs to try to come up with a plan for the next three years - to you I say good luck!

The NMC didn’t choose to change any rules when they stopped requiring the classes you are complaining about having had to pay for. That was the result of an appeal (possibly a lawsuit) by someone since those classes were not required by the CFRs. Thus, technically, you were never required to take them and you were just not smart enough to realize that so don’t cry about your wasted money.

If I were to take the time to reread those posts several times (which I’m not) I might be able to figure out what he was trying to say.

We all have a right to expect government agencies to use our tax dollars to run government programs in a manner that is lawful, reasonable, achieves intended goals, and is cost effective and fair. However, we are usually disappointed by the actual performance.

The USCG licensing, manning, admeasurement, and inspection programs are no exception. Very disappointing.

When the USCG come out with its International standard seafarer’s medical cards, let’s hope they do better than the US DOT has done with the truck driver medical cards.

The TSA is much worse.

This TWIC card program is silly, especially for anyone with an MMD, They are requiring far too many people that have no impact on any plausible security scenario to get TWIC cards. But I’m not interested in hearing any chicken manure complaints about having to spend $125 to get a TWIC card. I don’t know if its true or not, but I’ve heard they are talking about doing away with the TWIC program, because they’ve had to give out so many TWIC cards to immigrants who cannot be checked out in their home countries that the TWIC program has been rendered useless.

they’ve had to give out so many TWIC cards to immigrants who cannot be checked out in their home countries that the TWIC program has been rendered useless.

That’s what I’ve been screaming since the begging. All an immigrant has to do is have a letter from his consulate saying they are a find up standing person. I’m sure a few $100 slipped into their request to get said letter helps who ever decides what to put in the letter look over any indiscretion they might have had in there former country if they are even known.

Never mind it’s 6 years later and still no way to scan them.