[QUOTE=capt.cobb;42143]Updating this post, I did indeed go thru the “request for reconsideration” process, and after about a month and a half got an email stating my credential has been issued and it is in the mail. I don’t know which of my arguments or what part of my reasoning helped them change their mind, ( I made 5 different arguments as to why the limitation should be removed) but the out come is great. One other point, I did contact my congressman and ask him to put in a good word for me, whatever it was, I now have a Master of Towing with no limitations on it. Hoo- rah![/QUOTE]
In all likelihood, it was neither your arguments or input from your congressman. It was most likely the fact that someone else appealed the same issue not long before you and the precedent in that appeal is being applied to you.
To remove the 100-ton limit from a towing vessel license, you need to complete the apprentice mate (steersman) exam (or a course in lieu of). In your case, you’d already done that.