I think I’m good to go here and I’m using Chuck Kakuda as a licensing consultant. I have am apply for Mate of Towing with less than a 200 ton lic (100 ton and radar unlimited). I don’t need a big license because I work for the Army Corps of Engineers and our boats are smaller. I have the apprentice mate steersman certificate from CMTI, I have my completed TOAR from the Army Corps’s designated examiner, I have a letter from the Army Corps stating I’ve completed at least 30 days of training observation on towing vessels, I have a letter from my prior employer (Enterprise Towing & Salvage AKA TowBoatUS Chesapeake City) saying I have served at least 3 years as master and some other sea service forms documenting various small service as master. 46 CFR 11.429 says:
B[/B] If you hold any endorsement as a master of steam or motor vessels of any tonnage that is 200 GRT or less, except for the limited masters endorsements specified in 46 CFR 11.429 and 11.456, then you may obtain an endorsement as mate (pilot) of towing vessels by meeting the following requirements:
B[/B] Providing proof of 36 months of service as a master under the authority of an endorsement described in paragraph (e) of this section;
B[/B] Successfully completing the appropriate TOAR;
B[/B] Successfully completing the appropriate apprentice mate exam; and
B[/B] Having a minimum of 30 days of training and observation on towing vessels for the route being assessed, except as noted in paragraph (b) of this section.
However, the checklist on the NMC website checklist PDF uses the wording 1080 days as master. There is a big difference in that wording from what the CFR says and the NMC checklist… You can be a master for 3 years of a boat that leaves the dock three times, a million times or never. My letter from TowBoatUS says I’ve been employed as a master for over 3 years and have 400 8 hr days underway. My other sea service forms as master show an additional 100 days or so. I can dig up more master time if needed but I don’t want to if I don’t need to. Looking at the CFR, I’m good to go because I have documentation showing I was employed as a master for 36 months. Looking at the checklist on the NMC site, now I’m confused… Any insight?