It’s been a month, but we are talking about government policy. Sometimes, even for them, the hardest thing is to get those together in one room to discuss this issue. Hopefully, we get something soon. If it is an issue that Mr.Cavo will deal with directly, he most likely cannot (as a matter of ethics) discuss this in the forum.
Here is the emails from last month…
Sorry for the delayed response but I wanted to make sure I updated you on what we are doing to clarify the policy. We have received numerous requests to clarify and/or revise the policy, which was established some years ago, and we understand your concerns. I want to make sure the policy is clear so that you and other in the industry understand it, and more importantly my evaluators at NMC are consistent in the application of the policy. I’ve asked the Mariner Credentialing Policy Division at Coast Guard Headquarters to review this and I expect to have some information to you and others within the next few weeks.
CAPT David C. Stalfort
National Maritime Center
For more information on Mariner Licensing and Documentation go to http://homeport.uscg.mil and select Merchant Mariners under the list of Missions.
Sent: Tuesday, August 25, 2009 10:53 AM Eastern Standard Time
To: Stalfort, David CAPT
Subject: NMC policy 01-02
My name is Captain Thad G. Fendley. I am an Unlimited Master and serve as Captain on the AHTS Dino Chouest. I am writing you specifically regarding policy letter 01-02. Several disturbing issues have arisen lately regarding this policy, its interpretation, and its effect upon upgrading applicants. There has been an obvious change in precedence, and I’m trying to find out why in an effort to help those who are being directly affected. My concern is grounded in the fact that I have appealed a similar interpretation to Captain Fink and this exact issue was resolved. I’m not sure if a new GS or active duty employee has been added to your team, but it’s too coincidental for these many applicants, just over the last 30 days, to get the same contrary result out of NMC.
The particular issue in question regarding policy letter 01-02 is the OICNW requirements toward upgrading applicants. It seems lately that NMC is requiring “all” applicants for 500ton mate, 1600ton mate, and 3rd mate unlimited fulfill “all” requirements as if they were applying for an original issue without consideration as an upgrade. As you know, policy letter 01-02 was specifically written for guidance on OICNW requirements regarding the 500ton, 1600ton, and 3rd mates because these are the three licenses an original applicant can apply for which OICNW requirements do apply. There is also a section (11) that applies particularly to upgrading applicants that have a current STCW certificates. Sections (11a)(11b)(11c)(11d)(11e)and (11f) are very important for several reasons. First, you obviously need a current license and STCW. Second, your STCW is not currently endorsed as OICNW. Otherwise, if you had OICNW, Section (11) would not apply at all, and neither would the entire policy letter because you have previously met the requirements. Section (11) applies directly to those applicants, such as a 1600 ton Master that may have a current STCW, but only endorsed as RFPNW, upgrading to 3rd Mate.
My current company (Edison Chouest Offshore) has produced many mariners over the years since the draft of policy letter 01-02 based on Section (11), but this career path has affectively been closed by a recent interpretation of not allowing its application in any situation. That is simply not consistent with the policy, STCW, and recent history. I ask for this to be investigated further. All mariners expect consistency out of the National Maritime Center to make life decisions at the kitchen table. Thank You for your time.
Captain Thad G. Fendley