NMC Evaluations Subpar

Professional Mariner Forum
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Just applied to have my Chief Limited endorsement just to have it. You never know what doors may open. I’ve had my First Engineer Unlimited for quite awhile anyway and am roughly 6 months from my Chief Unlimited. Just went through PQEB evaluation and they “need additional information”. I contacted and they said I need to prove seatime while a chief limited is equivalent to a Second Unlimited…

So now I’m stuck having to go through reconsideration process due to the lack of awareness the evaluators possess.

Yes, I’m positive I put chief limited on my application. Double checked even. The NMC going to a third party evaluation process is insanity.

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The NMC does not have third party evaluators. Third party evaluators would be a huge improvement.

If NMC licensing functions were turned over to a third party contractor, such as the American company that efficiently does Liberia licenses, it would be a huge improvement.

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No point in bothering with a request for reconsideration. You’ll have Chief Unlimited long before your reconsideration would be processed.

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Wait they are telling you you need chief limited time to get chief limited? What does your additional information letter say word for word?

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No, they said I need more 1 AE unlimited time to get my chiefs license. I applied for chief limited, not unlimited just to have in my license.

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What exactly did they write in your Additional Information letter? (word for word) Are they accidentally evaluating you for Chief Unlimited, or are they saying you need more time for Chief Limited? The specific phrasing in the letter will help us identify where the evaluation is getting stuck.

While it may not apply to you. I see us unlimited folks get tripped up on limited-license sea time pretty often. The most common trip-ups are either not providing enough time (using only time from their last upgrade, as you do with unlimited licenses, when limited licenses typically need far more documented days) or not understanding the limited license credits for their time in the Academy if they are not hawspipers. I’m sure none of this applies to you, but I am curious about the wording of the AI letter, word for word. Note: It’s surprisingly common for a 1A/E to find themselves short on the total days required for Chief Limited. They are not equivalent.

It’s entirely possible the evaluator has it wrong. I’m just curious exactly what the evaluator is looking for.

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“To qualify for Chief Engineer of Motor propelled vessels, you must submit the

following:

*180 days as First Assistant Engineer.

Please provide 143 additional days as First Assistant Engineer while holding First

Assistant Engineer.“

This is copied and pasted from my letter. First Assistant Unlimited is a higher license than a Chief Limited oceans. Chief Limited is equivalent to Second Engineer unlimited. I do believe the evaluator has it incorrect. I decided I will resubmit instead of opting for reconsideration. You do not need more time on your First Unlimited to qualify for a Chief Limited. Unless there was a change somewhere along the way.

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Since the USCG lacks the competence and staff necessary to properly perform its duties in a timely manner, it needs fewer, more streamlined duties.

Simplify. Reduce the number of licenses and the volume of applications. There are far too many different licenses without a dime’s worth of difference between them. There are so too many different exams with no practical difference between them.

Chief Limited should be issued automatically (whether it’s asked for, or not) to all 2AE’s. The 3AE exam should include everything that’s in the Chief Limited exam.

Except maybe for Inland, the national licenses should be eliminated. Only STCW compliant licenses should be issued.

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If that is word for word what they sent you in regards to waiting on info, it looks like they are evaluating you for chief unlimited.

Have you attempted to call them/live chat to clarify? Its a shot in the dark but you could get lucky and actually get your evaluator on the phone.

The irony of this to me is, I got approved to test for my 1st assistant after sailing as a chief limited for a year, back in 2020. Not sure if that cross over option is still in place or not.

Worst case you are awfully close to having the time for chief unlimited.

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Precisely my point. They were evaluating for chief unlimited when I applied for my limited just to have on my license. You know the old saying “just another notch in the belt” sorta deal.

I did live chat and they informed me to apply for reconsideration. Timeline for this is 90 days it says. I know I would win on that one but as you said; I’m awfully close to unlimited so is it worth it.

Just thought I’d share my thoughts on the way they’re evaluating now. I do know the human factor of reading my application incorrectly. But their timelines are so long they really should be on top of their business.

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NMC has been a failing program since it first opened, but it has certainly gotten worse. Unqualified hires, no maritime expertise, deliberately understaffed, low moral, and high turnover of employees with no interest in the job who are just using it as a stepping stone to other government jobs. The USCG needs to admit failure and shut the NMC down.

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Yes, it sounds like the evaluator performed the evaluation for something different from what you requested—I have had that happen before, too. It is infuriating. You have to become an expert and spell it out for them sometimes. However, some evaluators are actually very good. Our system is overly complicated.

Two more questions:

  1. Did you submit all your career sea time, or just the time since the last unlimited license upgrade? You need to show at least 720 officer days in your app, and if you’re a hawspiper, even more.

  2. Are you an Academy graduate or a hawspiper? - It matters

I will break down the math for you or anyone else applying for Chief Limited. Forgive the long post. Also, forgive me if not all of it applies to you; it may help someone else. I have seen tons of folks get caught up on similar things.

Here are the sources I will use to calculate the minimum number of days required for C/E Limited.

Now, in your case, you probably have the required time being a 1A/E, but you need to spell it out for your evaluator! It’s totally possible to be a 1A/E without the required 720 days as an officer for C/E Limited.

While I have heard the same rumor in the fleet about 2A/E being equivalent to Chief Limited, unfortunatly it isn’t true and isn’t supported by the CFRs or USCG policy. That statement won’t gain traction with an experienced evaluator or the reconsideration team.

Your application must demonstrate that you meet the full C/E Limited required time, which exceeds the 2A/E minimum by a full year in every case and may exceed the minimum time required for 1A/E, so having it doesn’t automatically qualify you. (Even if logically, it should.)

The CFR Sea time Requirement for Chief Limited (46 CFR 11.518):

  • 1,800 days (5 years) total service in the engine room.

    • 720 days (2 years) of this service must have been as an engineer officer while holding an engineer officer endorsement.
    • 900 days (30 months) of the service must have been as a Qualified Member of the Engine Department (QMED) or equivalent position.

Please Note: Per 46 CFR, 1 month = 30 days; 1 year = 360 days (12 Month X 3O Day). Per the USCG Policy Engine, Officer service counts as QMED-equivalent time as well.

These are the cut-and-dried requirements for a hawspiper.

Academy Graduate Collage Seatime Policy (MSM Vol III Chapter 12.C.9): If the applicant is an Academy graduate, USCG policy grants credit for time in school toward Chief Limited:

  • 1,080 days (3 years) of engine room credit.

    • 720 days of this time are QMED-equivalent.

    • 360 days of this are unspecified engine and therefore equivalent to a wiper.

    • You then need to complete the remaining time required under the CFR above.

This is a USCG policy that provides essentially the same credit for college as would have been required for a hawspiper to earn 3A/E. I have found from experience that you must explicitly inform the evaluator that you are a (4-year) maritime academy graduate and request that this credit be applied. You must then show the remaining required sea time.

2A/E ≠ Chief Limited math

  • 3A/E requires 1080 Engine time (Or academy graduation)

  • +360 Officer for 2AE

  • = 1440 days, only 360 as an officer, a year short of the time for chief limited.

  • 2 A/E has also not taken the exams needed for C/E Limited.

This is the best case. Some 2A/E could be even shorter if the 720 needed days as an officer, for example, by applying the 2-for-1 unlicensed time rule toward an upgrade to 2A/E, they could be up to 1.5 years short of the officer time, which would carry forward to being short as 1A/E

The C/E Limited Academy Grad Minimum Time Math per MSM Vol III Chapter 12.C.9:

  • 720 QMED days credit (Academy Time Credit per MSM Vol III Chapter 12.C.9)

  • +360 Wiper days credit (Academy Time Credit per MSM Vol III Chapter 12.C.9)

  • + 720 days as an engineer officer while holding an engineer officer endorsement (which also counts as QMED)

  • = 1,800 Total Days (1,440 QMED Equivalent)

  • This is 720 all officer days post graduation

  • This meets the CFR-required 1,800 engine days and exceeds the required QMED days by quite a bit.

  • Most people who get 1A/E who sailed 100% as an officer after 3A/E would qualify for C/E Limited under this calculation. But there are ways you could be short, as discussed above in the 2A/E example.

  • The checklist implies there may be another time requirement; see below.

Chief Limited Academy Grad per Checklist (MCP-FM-NMC5-41), one bullet point might imply that an additional 180 days are required of Academy Grads. If read this way:

  • 720 QMED days credit (Academy Time Credit per MSM Vol III Chapter 12.C.9)

  • +360 Wiper days credit (Academy Time Credit per MSM Vol III Chapter 12.C.9)

  • + 720 days as an engineer officer while holding an engineer officer endorsement

  • + “180 days as QMED or equivalent (any licensed service may also meet this)”

    • Note: The checklist is unclear whether these 180 days are a separate requirement or if it’s like my last math example, because your license time meets both. In this math example, I am making it separate for demonstration purposes.

  • = 1,980 total days (1,620 QMED equivalent) -

  • This is 900 all officer days post graduation

If you are required to have a separate 180 days to fulfill the QMED requirement, as the checklist might imply, you dont qualify for Chief Limited until 180 days after the minimum for 1A/E. I have seen evaluators take both sides on this because of the ambiguous wording.

I hope the USCG updates the checklist for clarity. I believe it should be 720 officer days post-graduation, not 900 as in the second example. All Officer time should also count toward your required 30 months of QMED equivalent, so it’s redundant to make it a separate QMED time bullet point on the checklist. Most 1A/E’s should qualify for chief limited.

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