[QUOTE=tugsailor;99267]
I believe that would simplify the system to three levels of licenses: 500, 3000, and unlimited. There needs to be a logical and practical upgrade path from one level to the next.
Limited tonnage mariners need to get tonnage credit for the I.T.C. tonnage that more accurately reflects the actual size and complexity of the vessels. Tug and barge guys need to get at least some credit for the combined tonnage of the tug and barge(s).[/QUOTE]
My 2/c here is that the tug/barge guys on the wire should get time counted, maybe around 50% and the ATB a higher but not 100%. Maybe 90%.