[QUOTE=zacharyn;138287]I’m very thankful the G captain forum exists and I’ve learned a lot from reading posts here.
- I wish people would read the available material before randomly deciding to throw in their two cents. Wading through garbage posts to get the truth gets old.
- I hope this is not the way the coast guard is going to choose to interpret their new NVIC and check list.
I hope my post encourages logical discussion of how the actual upgrade process will play out and that mariners will write about their experience trying to upgrade.
Here is the checklist called “STCW II/2-MASTER 3000 GT OR MORE
MANAGEMENT LEVEL § 11.305” so that you can read it yourself before commenting.
Here is the 204 page NVIC describing it all in detail.
I understand Mr. Cavo’s simplification of the upgrade process but to me it seems more complicated than that. The old Master “Unlimited” now seems to be called Master 3000 GT or more according to the checklist there is a route to upgrade directly from “Master less than 3000 GT” to “Master 3000 GT or more”
Here it is verbatim:
"If holding STCW as Master of 500 GT or more and less than 3000 GT, IAW
11.311, are eligible to apply for this endorsement upon:
- Completion of 180 days of sea service under the authority of the
endorsement as Master of 500 GT or more and less than 3000 GT;
- Provide evidence of meeting the standard of competence specified
in Section A-II/2 of STCW Code (not previously completed); AND
- Approved training listed below (not previously completed )"
1.To me 180 days of sea service means 180 days sailing while holding Master less than 3000 GT. Will the NMC interpret this in some strict way like “[B]under the authority[/B]” meaning you have to be sailing as master for all the sea service?
2. This makes no sense to me because if you already hold Master less than 3000 GT haven’t you already had to meet STCW A-II/2?[/QUOTE]
You have ignored 46 CFR 11.201(a) which states, in relevant part:
[I]…An applicant for any STCW endorsement must hold the appropriate national endorsement unless otherwise specified.[/I]
Obviously, the appropriate national endorsement is exactly what the title of the STCW endorsement indicates, one for Master that authorizes service on vessels of 3,000 GT (or 1,600 GRT) or more. There are only two of those, Master of Self-Propelled Vessels of Unlimited Tonnage (a.k.a. “Master Unlimited”), and Master (OSV) endorsed for a tonnage of at least 3,000 GT and/or 1,600 GRT. As I noted previously, the requirements for the national endorsement of in 46 CFR 11.404 have not changed. So again, this regulation does not provide a new way to get Master Unlimited. All it adds is a path for a Master for OSVs of 3,000 GT or more to get the corresponding STCW endorsement.
For an example of “unless otherwise speified” as used in 46 CFR 11.201(a), see 46 CFR 11.337(d).
[QUOTE=zacharyn;138287] The old Master “Unlimited” now seems to be called Master 3000 GT or more according to the checklist there is a route to upgrade directly from “Master less than 3000 GT” to “Master 3000 GT or more”[/QUOTE]
You are confusing the STCW endorsement with the national endorsement (license). The title of the national endorsement has changed, but not as you suggest. It has changed from [I]Master of Steam and Motor Vessels of Any Gross Tons[/I] to [I]Master of Self-Propelled Vessels of Unlimited Tonnage[/I]. The title of the STCW endorsement has [I]not[/I] changed.
As noted previously, the national and STCW endorsements are not the same and have their own requirements. You can get any national endorsement (license) without holding an STCW endorsement, but as I just noted, in almost all cases, the reverse is not true, you must hold an appropriate national endorsement to get an STCW endorsement (the only exceptions I can think of without looking them all up are Electro-Technical Officer, Electro-Technical Rating, Basic Training, and STCW security endorsements).
As noted above, to use the route for an STCW endorsement as Master for less than 3,000 GT to 3,000 GT or more, you must hold or concurrently qualify for a national endorsement as Master for a tonnage of 3,000 GT (1,600 GRT) or more.
[QUOTE=zacharyn;138287]This makes no sense to me because if you already hold Master less than 3000 GT haven’t you already had to meet STCW A-II/2?[/QUOTE]
Notwithstanding that you did not have to do anything (i.e. training and assessment) in order to/ “meet” STCW Regulation II/2, you did so only for less than 3,000 GT. Since we have been issuing STCW 95 endorsements, we have had separate endorsements for less than 3,000 GT, and for 3,000 GT or more. The current Master 500/1600 GRT with a corresponding STCW endorsement has [I]not[/I] met II/2 for 3,000 GT or more. In other words, your STCW endorsement under Regulation II/2 has a limitation to vessels of less than 3,000 GRT and to remove it you must meet the requirements for an endorsement for 3,000 GT or more.
[QUOTE=zacharyn;138287]…“Additional training listed below” according to the checklist is:
Advanced Shiphandling 11.305
Advanced Stability 11.305
Advanced Meteorology 11.305
Leadership and Management Skills 11.305
Search and Rescue 11.305
Management of Medical Care 11.305 [/QUOTE]
There are also assessments. You do not have to complete all of them for Master 3,000 GT or More, but need to do those that are different for Master 3,000 GT or More. See Enclosure 2 of NVIC 10-14.
[QUOTE=zacharyn;138287]…I wonder if the USCG will come up with an ITC equivalent for this tonnage so that Masters with tonnage limitation on their 3000 GT or more license can work on vessels with ITC only measurements.[/QUOTE]
See 46 CFR 10.232(i). 1,600 GRT is considered to be equivalent to 3,000 GT and 200 GRT is considered to be equivalent to 500 GT. Even these “equivalencies” are a stretch as the difference in GRT and GT is vessel specific and unlike kilowatts (kW) to horsepower (HP), there is no formula to convert one to the other (1.33 HP = 1.00 kW, see definition of [I]kilowatt[/I] in 46 CFR 10.107)
[QUOTE=zacharyn;138287]Has anyone submitted an application to upgrade and heard back from the NMC or better yet gone through the whole upgrade process?[/QUOTE]
If you look at the overall processing times noted in the NMC’s monthly performance report and the discussion about it here on gCaptain, it’s not likely that anyone who submitted an application after March 24, 2014, has made it through the evaluation process.