Messed up on my paperwork and I’m in compliance after I sent in the letter to fix they hit me with I need a 200 ton but cfr says I don’t

Maritime Topics Maritime Training & Licensing
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So I hold a 100 ton near costal and I’m trying to upgrade to mate pilot I’ve done my TOAR I have my 1080 days as master did my apprentice mate class and passed basic firefighting. There was an issue with my sea service form where I messed up and lapsed sea time I own a charter boat company and I run my boat when I’m home and when I’m away for work I hire another captain to run the boat for me I accidentally opened his sea service excel file that I keep on record to 1 pay him and 2 in case he were to ask me for a letter so I opened his up and put his time on my small vessel form on accident. So now I’m in compliance, also I worked on a tug that weighed 106 tons and I ran as master reason being the boat had a work exclusion letter saying an unlicensed master could run within a certain body of water which I was in, but I forgot to send that letter in I was told they weren’t going to acredit me with those days because it was out of my scope and I sent that letter saying I could run because the company had a work exclusion letter from cg and an explanation as to why I lapsed on my sea service form and sent in an updated one this should get me out of compliance correct ???..…recently I got an email saying I don’t qualify for the mate pilot because I don’t hold a 200 ton masters but I’m confused because the CFR they cited which I posted above says any master under 200, can someone please give me an idea how long I’m going to be in compliance or if the evaluator I got is wrong?

The cfr states

Those holding any endorsement as a master of self-propelled vessels of any tonnage that is less than 200 GRT, except for the limited masters endorsements specified in §§ 11.429 and 11.456 of this subpart, may obtain an endorsement as mate (pilot) of towing vessels by meeting the following requirements:
(1) Providing proof of 36 months of service as a master under the authority of an endorsement described in this paragraph.
(2) Successfully completing the appropriate TOAR.
(3) Successfully completing the appropriate apprentice mate exam.
(4) Having a minimum of 30 days of training and observation on towing vessels for the route being assessed,

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The nmc is f***** when it comes to tug licensing. They read whatever they feel like into the cfr’s and it changes from year to year. I reached out to MMSEAS, when I had issues with my licensing, it was totally worth it. They might be able to help with the finer points of your application.

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Call your evaluator and drop the CFR on them. I’ve had to do this multiple times, as most of them have no clue what they are even evaluating. This is also assuming whatever CFR you cited is accurate and true to your case, because frankly, your shit was painful to read without punctuation.

4 Likes
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After a search of gCaptain threads I found your apparent situation has been discussed and responded to in previous threads.

I refer you to a December 2012 thread 100 ton master to 200 ton mate of tow question Maritime TopicsTugs & Towing and the response provided by Jdcavo to the following statement:

“U need to get ur 200 ton mate before they issue u ur mate of towing. Did u take the apprentice mate class?”

*The response was “*Not if he has 3 years of experience as Master. If he does, he can get Mate of Towing Vessels with 30 days on a tug and completion of the TOAR.”

It looks like Mr. Cavo response was following a similar regulatory citation.

2012 11.465 (e) "If you hold any endorsement as a master of steam or motor vessels of any tonnage that is 200 GRT or less.

2024 11.465 (f) holding any endorsement as a master of self-propelled vessels of any tonnage that is less than 200 GRT.

Key will also be your sea letters demonstrating the 1080 days service as a master under the authority of your endorsement.

If I have misread, misinterpreted, misspoke or mislead you: we should get a response to my reply.

It looks like your evaluator was not necessary familiar with your request and decided it need higher authority for the interoperation of regulation.

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See no comments on what I wrote. So i would recommend you now follow the current and past treads on the reconsideration and appeal process. Just in case thinks don’t go the way you expect.