Mate of Towing Licensing Question

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?

Thanks,

Jeff

You need 1080 sea time days service as a master of a vessel I believe.

[QUOTE=HooliganMariner;156945]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?[/QUOTE]

It’s time served as Master, not the total amount of time that passed from your first day until your last day. For example, if you started working on April 1, and worked until April 30, but had 10 days off, you have 20 days served as Master, not 30.

From 46 CFR 10.107, a year is considered to be 360 days, and a month is 30 days.

NMC’s checklist is correct.

Obviously, This guy did not like the answer when his license consultant told him he is not qualified for the towing license. So now here comes here hoping someone will tell him what he wants to hear.

Its time for a USCG crackdown on fraudulent applications for towing licenses.

I am qualified and I have the 1080+ days as master but thanks. I was just confused on the wording between the cfr and the checklist.

Thanks for the clarification.

[QUOTE=HooliganMariner;158006]I was just confused on the wording between the cfr and the checklist.[/QUOTE]

Any time the CFR talks about length of service they (obviously to most of us) mean documented sea time.

“36 months of service as a master under the authority of an endorsement described in paragraph (e) of this section”

Means 36 months (1080) days underway as master.

Wouldn’t 20 12 hour days equal 30 8 hour days ? Is this still true each 12 hour day counts as 1.5 days

[QUOTE=Tugslasthitch;172151]Wouldn’t 20 12 hour days equal 30 8 hour days ? Is this still true each 12 hour day counts as 1.5 days[/QUOTE]

Only on vessels authorized to operate on a 2-watch system.

which would be most 4man crewtugs

[QUOTE=Tugslasthitch;172162]which would be most 4man crewtugs[/QUOTE]

absolutely, but you get punk ass kids on here saying their drill ship time is time and a half and looking for a fight when a USCG evaluate correctly says no, so its important to make the differentiation.

Thought they’d already been giving drill ship DPO’s time and a half?

[QUOTE=Slick Cam;172183]Thought they’d already been giving drill ship DPO’s time and a half?[/QUOTE]

See 46 CFR 10.232(h)(2): [I]On vessels authorized by 46 U.S.C. 8104and 46 CFR 15.705, to operate a two-watch system, a 12-hour working day may be creditable as 11⁄2 days of service[/I]

Does the de only have to sign the common elements meaning the task marked with X and captains not holding a de are able to sign non common task?

[QUOTE=Tugslasthitch;177102]Does the de only have to sign the common elements meaning the task marked with X and captains not holding a de are able to sign non common task?[/QUOTE]

No. Only an approved DE can sign for any part of the TOAR, including the common elements. A common element means that the task is the same for all routes, and if you get it signed on one route, or already hold an endorsement for one route, you don’t have to re-do the common elements for another route.