Question for Mr. Cavo re: 46CFR11.422 "Maximum Tonnage" and Tonnage Increments

Maritime Topics Maritime Training & Licensing
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Given the details as outlined in your issues, if the appeal came across his desk it wouldnt take much to figure out it was you. You might not be as anonymous as you think.

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It seems like he almost never chimes in on any thread that is addressed to him, probably to try to get people to stop doing that.

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[QUOTE=Capt. Phoenix;90077]It seems like he almost never chimes in on any thread that is addressed to him, probably to try to get people to stop doing that.[/QUOTE]

Thanks guys; I’ll try to PM him & try Richard Block as well. This is just becoming a horror show: maximum tonnage = minimum tonnage; upgrade = downgrade. Should’ve just gotten my Yachtmaster Commercial! :wink:

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I have and need to continue avoiding getting involved in this discussion. Since you already have an application at NMC, and NMC has given you an appeallable decision, I need to recuse and stay out of this. My office handles appeals of NMC decisions and this has the potential to come to us on appeal. Thus I need to remain uninvolved to preserve the impartial, unvbiased appeal process.

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[QUOTE=jdcavo;90154]I have and need to continue avoiding getting involved in this discussion. Since you already have an application at NMC, and NMC has given you an appeallable decision, I need to recuse and stay out of this. My office handles appeals of NMC decisions and this has the potential to come to us on appeal. Thus I need to remain uninvolved to preserve the impartial, unvbiased appeal process.[/QUOTE]

Thank you for your reply, sir; I do not currently have an open application. After I was told to acquire more sea service, my previous application timed out while doing so; I posed my inquiry based on some confusion about the definition of “maximum tonnage.” I will re-pose 3 quick questions & if you could give give any input, I would be very grateful:

  1. While the “Maximum Tonnage” required by 46CFR11.422 is calculated using the 25% (or 50%) of required sea service occurring on largest vessels, does NMC currently interpret this to mean the Tonnage Increment is determined by the a) MINIMUM TONNAGE or b) AVERAGE TONNAGE of the vessels upon which this 25% (or 50%) took place?

  2. If NMC’s current interpretation is 1.a. above, this would give the frankly non-sensical result of requiring fewer sea days on smaller vessels to become a 46CFR11.418 Master NMT 500GRT Oceans than to become 46CFR11.424 Master NMT 200 GRT Oceans; how can this be possible?

  3. Again, if NMC’s current interpretation is 1.a. above, it clearly differs from that of my evaluator at the local REC for my last 2 issuance/renewals. Would renewal of the Tonnage Increment of the license I CURRENTLY HOLD be in jeopardy if re-calculated to be lower under this interpretation per 1.a. above?

Many thanks for your time, JGB