License?

I have a 100 ton inland license and only need my 90 days of recent time to upgrade to a 500 ton. The company I work for now has several pushboats that I shuffle around light, I do not have a towing endorsement. Will my time moving the boats around count towards my upgrade or am I outside the scope of my license by moving these vessels around light? I have looked everywhere and can’t find a answer. Any help would be greatly appreciated.

I went through the same thing a few years back. The answer I received from the coast guard was that if it’s a towing vessel, regardless if you are light or pushing/towing, you need a towing endorsement(unless under 26ft). So, if you are trying to use that time as mate/master time for your upgrade it would not count as such. However, if you just need general sea days it should count provided it meets the requirement of a ‘day’ (four hours or whatever it is) and it is not written in such a way that you were operating out of the scope of your credential.

As mentioned, your operation of a towing vessel is illegal. As such, your time only counts as time as Deckhand. Make sure you don’t submit a sea service letter that says you were OPERATING. That would cause unwanted attention and questioning and probably a letter from the CG to the company explaining why this is happening.

So what makes a towing vessel a towing vessel? Is there a towing endorsement on the documentation? When I still worked on tugs they just said coastwise (but you could run them with a hundred ton) just like any other boat. If there isn’t anything about towing on the documentation I would think as long as the seatime letter didn’t use words like tug or towing when describing the vessel, you would be ok.

I will have to find the specific wording. A vessel which is engaged in the towing industry has been under increased scrutiny in the last 10 or 15 years. Part of the scrutiny has been over the licensing and operations. No longer is the blurring of use (whether towing or not) accepted.

Then you are crossing the line from just not being complete with being deceptive.

The coast guard knows if it’s a towing vessel or not. I’m not sure how but they do. So if you use the official number off a tug and try to pass it off as a ‘normal’ the coast guard will catch on to what you are doing. This also applies on the flip side. If you want to get a towing license and the vessel is not coming up as a towing vessel in the coast guard’s computer bank, you will have an extremely hard time getting a towing endorsement. Best thing to do is be honest about your service…

[QUOTE=djstress;79235]I have a 100 ton inland license and only need my 90 days of recent time to upgrade to a 500 ton. The company I work for now has several pushboats that I shuffle around light, I do not have a towing endorsement. Will my time moving the boats around count towards my upgrade or am I outside the scope of my license by moving these vessels around light? I have looked everywhere and can’t find a answer. Any help would be greatly appreciated.[/QUOTE]

On ANY towing vessel, even a light boat, you need a license mate or master of towing vessels (or have a license for 500 GRT or more, and have 30 days on a towing vessel and a completed TOAR). Not only will your time not be accepted, the matter will probably be referred to a Coast Guard field unit to investigate improper manning.

Alright I am quite confused here. What legally makes a vessel a towing vessel in the first place? I know about the 26’ rule but I have never actually seen it in writing. I can use a 58’ purse seiner to tow a scow just like I can use a 58’ vessel designed to tow or does suddenly my seiner become a tug then? They both have winches and enough HP to do the job, they are both uninspected vessels, they both have coastwise trade on their documents. Where in subchapter C is there a class of towing vessel and why is it restrictive. I tow a skiff through the water with my seiner and I’m not a tug. Why can’t I pull something through the water with whatever vessel I can find that safely gets my job done? Why do you call a vessel a tug when it doesn’t have a tow? If I run my seiner light it isn’t a tug and the seatime is valid and nobody says boo. Why does our guy have to be afraid to just run a boat around a yard?

Isn’t that exactly what is going on here with this fellow?

This is really convoluted. A towing vessel whether towing or not is still a towing vessel. It does not change use whether with or without a tow. The example of towing the skiff is not the same. The seiner is not engaged in towing for hire. That is part of her ordinary business.

[QUOTE=cappy208;79322]This is really convoluted. A towing vessel whether towing or not is still a towing vessel. It does not change use whether with or without a tow. The example of towing the skiff is not the same. The seiner is not engaged in towing for hire. That is part of her ordinary business.[/QUOTE]

But what constitutes a “towing vessel” and am I prohibited to tow a scow from one dock in Alaska to another if the scow is not part of my vessel’s equipment?

Or better yet, there are a lot of old tugs out there being used as overnight six pack charter vessels. They still have H bitts, winches, and original direct reversible engines. If they are taking passengers for hire they have a coastwise documentation. Does this mean the people running these have to have a master of towing because they are operating a light tug?

I believe the ABS documentation and COD declare a tug as a “towing vessel”.

You would probably be prohibited from towing that scow “for hire”.

[QUOTE=Capt. Phoenix;79348]I believe the ABS documentation and COD declare a tug as a “towing vessel”.

You would probably be prohibited from towing that scow “for hire”.[/QUOTE]

ABS doesn’t count and Certificate of Documentation only has oil screw vessel then it’s endorsements such as coastwise trade, registry, fisheries, etc…

I have been running a tug, assisting a Army Corps dredge on the Mississippi, I don’t have a MOT (yet) , The push boat is documented as a "passenger vessel"
I guess thats why my company told me that my 200 ton lic.(great lakes&inland) would be OK. But my question now is - can I use the sea time “on a tug” for my pilots endorsement ? I have most of my TOAR completed, and over 1000 days sea time. How do I list my “capacity” for my time on this boat ? time on a tug, or passenger vessel ?

I guess that is OK, until you have an accident. Then the CG will ask to see your MoT endorsement. Then the shit will hit the fan!

What if you had a small single screw tug under a hundred tons that you used to tow disabled yachts and for light salvage work. Couldn’t you run this boat with a hundred ton and a towing assist endorcement as long as you never towed any barges?

There are vessel classed as towing vessel by ABS, but are OSVs by Coast Guard. No towing endorsement required. The same vessels tow 45,000 tons of steel through the oilfields in the GOM…go figure.

A vessel does NoT have to be ABS classed to be a towing vessel.

The litmus test is: if the towing vessel is being paid for the movement of. Or, is the crew being paid to move it. Is it for hire?

I have seen a steel hulled fishing most get stripped of fishing gear. Get airplane tired up and become a tug. The mention of an old tugboat being a 6pak tour boat is true too. It is NOT in the towing industry now so doesn’t need a MOTV. But an ordinary Tug being shifted from one towing job to another DOES!

Iirc, this has to do with the Pilot regulations. Since all vessels OVER 1600 tons must be under the direction of a first class pilot the towing industry got accomodation from The CG to allow towing vessel operators to ‘act’ as their own “Pilot”. This is for barge tonnage from 1,600 to 10,000 GT. Over 10,000 GT it MUST be a fully licensed first class pilot. These ‘under 10,000 Tons’ are not licensed as a pilot, they just ACT as one. Part of this trade off was to specify that towing vessels MUST at all times be under the direction of a licensed MOTV. It used to be called an OUTV. Ring any bells?

[QUOTE=anchorman;79389]There are vessel classed as towing vessel by ABS, but are OSVs by Coast Guard. No towing endorsement required. The same vessels tow 45,000 tons of steel through the oilfields in the GOM…go figure.[/QUOTE]

The USCG does not understand the laws, they only enforce them. The guy in charge of the Towing Program at HQ is a good friend of mine but was never qualified underway on the bridge. He was a Marine Inspector and qualified in the Engine Room. He never towed anything but could inspect things making him an expert. Great guy but to us that makes no sense but that is the way it works there when nobody qualified at doing it applies for the job.

I can’t afford the pay cut.

[QUOTE=jdcavo;79315]On ANY towing vessel, even a light boat, you need a license mate or master of towing vessels (or have a license for 500 GRT or more, and have 30 days on a towing vessel and a completed TOAR). Not only will your time not be accepted, the matter will probably be referred to a Coast Guard field unit to investigate improper manning.[/QUOTE]

No they won’t. It may get submitted to them because unless they are bored but they cannot keep up with the items they find let alone items bought to their attention.

Besides per the CFR’s, the federal government is required to enforce, they are not required to investigate.