I’m a Master NMT 200GRT, currently in grace period while attempting an Increase In Scope from NC to Oceans, and have a question for you after encountering some difficulties in the process. I’m a yacht skipper, but managed to earn the minimum number of days on a 300GT tallship needed for my initial license to be Aux Sail Master NMT 100GRT Inl. + OUPV NC + Mate NMT 200GRT NC; though my subsequent service was only on small vessels (<50GRT), I had no trouble attaining a RIG to Master NMT 200GRT NC (& later renewal of same). I hold all STCWs needed to at least attain 500GRT/1600GT Master Oceans.
After applying for my latest Increase In Scope, which by coincidence has been my 1st opportunity to deal with NMC Martinsburg, I was 1st told that 12-hour days could no longer be granted for passagemaking in yachts, so I had to obtain further Oceans service. After doing so, I was then told that I’d need further “Maximum Tonnage” service for increasing the Scope of my current license to Oceans. I felt this was unusual, since I’d never heard of providing add’l tonnage for a simple Increase In Scope, as compared to a Raise In Grade to higher tonnage & had not been asked to do so for my previous RIG.
To gain additional tonnage, I’ve been serving underway/dayworking on a ~7200GT vessel in Reduced Operating Service; my understanding of 46CFR11.422 was that I merely needed to serve enough days on this larger vessel so that the “Maximum Tonnage” of the 540 days I’d served on the largest vessels would come to an AVERAGE > 100GRT. But after reviewing my correspondence w/NMC, I get the impression they feel an Increase In Scope can only be granted if all 540 days are served on vessels with a MINIMUM TONNAGE > 100GRT.
I find no support for such a requirement in 46CFR11.422, unlike the minimum tonnage service requirement for, e.g. Master NMT 500GGRT Oceans in 46CFR11.418. Indeed, such an interpretation would lead to the frankly bizarre result of allowing a Mate NMT 100GRT NC, with only an extra 360 days on no more than a 51 GRT vessel, to leap to Master NMT 500GRT Oceans (assuming all other licensing requirements were met); while a Master NMT 200GRT NC who served the rest of his career on a 99GRT vessel could never attain a simple Increase In Scope to Master NMT 200GRT Oceans.
I truly hope I’ve misunderstood NMC’s interpretation of “Maximum Tonnage” under 46CFR11.422; would you be able to shed any light on this matter? Many thanks for your time, JGB
It should have nothing to do with you’re sea time from your last upgrade to now, it is total sea time. Look in the CFR and see what the requirements are for master 200 grt ocean and see if you meet those.
Think you mean over 151 GRT; yes, if Maximum Tonnage for 270 days can be averaged to > 151 tons. But no, if each day of 270 had to be on a vessel w/a MINIMUM TONNAGE > 151 GRT.
So again, what does “Maximum Tonnage” really mean? If each day of 270 had to be on a vessel > 151 GRT, that’s crazy; means sea service for Master 500 GRT Oceans could be obtained w/less days on smaller vessels than needed for Master 200 GRT Oceans.
It seems pretty simple to me, it doesn’t say average anywhere. If you have 270 days on a vessel over 151 grt or 540 days in a vessel over 100 get then you have your required tonnage. Otherwise you don’t.
Do you have enough time and tonnage to go to 500 ton master?
[QUOTE=“JGB;89863”]means sea service for Master 500 GRT Oceans could be obtained w/less days on smaller vessels than needed for Master 200 GRT Oceans.[/QUOTE]
[QUOTE=JGB;89774] I hold all STCWs needed to at least attain 500GRT/1600GT Master Oceans.[/QUOTE]
There is no such license. 500GRT is it. No ITC designation or equivalence.
[QUOTE=Capt. Phoenix;89869]That’s basically how it is…[/QUOTE]
Ya; understand the term “average” is never used, but nor is the term “maximum tonnage” ever defined; if it actually means “minimum tonnage” of vessel upon which 270 days are served, why doesn’t the reg simply state that, as in 46CFR11.418, e.g.?
Clearly, if Phoenix is correct, then I’ve badly misunderstood the regs, but why would anyone ever ASS-U-ME it would be harder to make 200GRT Master than 500 GRT Master?
And no, I don’t think I have enough time for 500GRT Master, since almost all my time is on yachts; Mr. Cavo, please chime in!
Maximum tonnage seems simple to me. If you served a bunch on a 45 grt boat, some on a 88 grt boat, and some on a 187 grt boat then 187 is the maximum tonnage.
[QUOTE=Capt. Phoenix;89878]Maximum tonnage seems simple to me. If you served a bunch on a 45 grt boat, some on a 88 grt boat, and some on a 187 grt boat then 187 is the maximum tonnage.[/QUOTE]
But by your definition, 187 isn’t the “maximum tonnage”, unless you spent > 270 days aboard. In theory, if you spent 268 days on a 187GRT, 1 day on on that 88 & the rest on that 45, you’d be only a 100GRT Master by your reckoning, but a 200GRT Master by mine.
Anyway, hoping Mr. Cavo will chime in; if your reckoning is correct, it means that I wasn’t even entitled to the license I’ve already held for nearly 10 years!
That is correct. Go to the nmc website and download the checklist for 200 master oceans. It spells out the tonnage requirements quite clearly. You are also correct in that the tonnage requirements for a five hundred ton license are less than that for a 200 ton license. Strange but true.
[QUOTE=JGB;89875]Ya; understand the term “average” is never used, but nor is the term “maximum tonnage” ever defined; if it actually means “minimum tonnage” of vessel upon which 270 days are served, why doesn’t the reg simply state that, as in 46CFR11.418, e.g.?
Clearly, if Phoenix is correct, then I’ve badly misunderstood the regs, but why would anyone ever ASS-U-ME it would be harder to make 200GRT Master than 500 GRT Master?
And no, I don’t think I have enough time for 500GRT Master, since almost all my time is on yachts; Mr. Cavo, please chime in![/QUOTE]
Time is time, whether yachts or otherwise.
For the 500 GRT it just needs to be over 50 GRT.
Ya, Shadow; thanks. Did look at checklist, but it’s been noted many times here how checklists have been wrong & my point is that the reg does not state what checklist does.
The checklist interpretation does make it harder to get a 200GRT than a 500GRT, which again is non-sensical & would not have entitled me to my last 2 issuances. Hopefully Mr. Cavo can give input.
[QUOTE=Flyer69;89898]Time is time, whether yachts or otherwise.
For the 500 GRT it just needs to be over 50 GRT.[/QUOTE]
Ya, time is time, but yachts are yachts. They hit us with something called a “fineness ratio” so rarely have I ever driven anything bigger than 50GRT; I’m a sailor, like with sails.
But by your definition, 187 isn’t the “maximum tonnage”, unless you spent > 270 days aboard. In theory, if you spent 268 days on a 187GRT, 1 day on on that 88 & the rest on that 45, you’d be only a 100GRT Master by your reckoning, but a 200GRT Master by mine.[/QUOTE]
187 is the maximum tonnage you sailed on whether or not you have enough time on it to qualify for your license.
[QUOTE=JGB;89902]Ya, time is time, but yachts are yachts. They hit us with something called a “fineness ratio” so rarely have I ever driven anything bigger than 50GRT; I’m a sailor, like with sails.[/QUOTE]
Man, you are losing me here, wtf is a fineness ratio???
And as far as averaging your time and tonnage, I am really not getting it. The regs. state so many days over so many tons. If you have enough days on big enough vessels you meet the seatime qualification. If all your time is on these sailboats under 50 GRT, you arent gonna get the big license you want.
[QUOTE=Capt. Phoenix;89905]187 is the maximum tonnage you sailed on whether or not you have enough time on it to qualify for your license.[/QUOTE]
Ya, I agree that would be a more commonsensical definition, but it’s not used in that fashion; for the checklist interpretation of the rule to be correct, “maximum tonnage” would need to be defined instead as as “tonnage of the smallest vessel out of the largest vessels upon which you can show 270 days of service.” That just doesn’t seem to be the most straightforward interpretation, especially since it results in requiring more days on larger vessels than needed for a higher grade license.
[QUOTE=JGB;89909]That just doesn’t seem to be the most straightforward interpretation, especially since it results in requiring more days on larger vessels than needed for a higher grade license.[/QUOTE]
Are you referring to the 200GRT as opposed to the 500 GRT?
They hit us with something called a “fineness ratio” so rarely have I ever driven anything bigger than 50GRT; I’m a sailor, like with sails.