Renewal wait time

Has anybody dealt with the NMC lately? I have a friend that submitted his application on the 30th of March and as of yesterday, they had only knowledged that they received it and it’s in the queue.

I walked mine into the REC March 12th . Received word its ready for printing April 30. Had a little problem with the radar certification : Make sure you send a recent radar cert or your seatime letter states that your vessel has radar and you are proficient in the use of it .

@GOMariner I thought since they took away the requirement to renew your radar cert that you didn’t need a Cert for it anymore? When I renewed last year I had just renewed my radar cert and then the next month they removed the requirement to renew. Go figure. So they told you that your sea time letter has to say you’re proficient or you need the cert?

I had almost 700 days sea time as a Master on a unlimited tonnage ship. I called and explained and they quoted I needed 360 additional days in a position that routinely uses radar for navigation and collision avoidance or current radar cert.they referenced 46 CFR.11.480(d) and policy letter 03-19. I took a radar recertification in 2018 so sent that. I would recommend all sea time letters reference that you use are in a position that routinely uses radar for navigation and collision avoidance. I am going to throw ECDIS and GMDSS just in case that comes into question.

I think you should have just pointed NMC to their own policy Letter (CG-MMC-Policy Letter No, 03-19):

Mariners will be considered to have met the requirement in 46 CFR 11.408(g) for relevant service routinely using radar for navigation or collision avoidance if they have at least one year of service as master or mate in the previous five years that was obtained on the following vessels that are required to be fitted with radar, tonnage thresholds expressed in terms of “gross tons” are applied using GRT, if assigned and GT ITC if GRT is not assigned…

The letter goes on to list all the specific vessels (just about anything over 1600 GRT in ocean or coastwise service and OSVs over 100 GRT). It also specific states that:

Mariners who have served on vessels other than those listed in paragraph (b) above, or in capacities other than master or mate should provide documentation of their relevant service…

I called a couple of times ,I explained the vessel I worked on(drillship) the tonnage , that we had radar I used on a regular basis it did no good in the end it was easier to send the cert … I will just make sure my next sea time letter specifies the radar service .

It was easier because NMC doesn’t apply common sense when evaluating an application. Sometimes I think the evaluators’ performance evaluations must be based on how many times they can deny a license before they finally approve it. Why does it have to be this way? Why can’t a Mariner get the benefit of the doubt instead of constantly being harassed?

Evaluations used to be done at the REC and one could discuss face-to-face issues with the evaluator, correct?

Now all evaluations are done by group of people at the NMC, but the REC are still open and staffed. Has the staffing count at the REC been reduced to eliminate the evaluators that now sit at the NMC?

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Maybe the “E” in REC might be be one reason they are open. The staffing levels were adjusted when evaluations moved to NMC - 12 years ago.

So, please share some of your wisdom from the puzzle palace. What does the future hold for the RECs? With the imminent changes coming down the road with charts and other advancing technologies, they can’t keep testing Mariners on the 1983 tides and currents.

What is the real plan, JD?

I’ve survived way too long to take the bait on this one, or has an ex-coach of the NY Giants said and earned his nickname, who do you think I am, Charlie the tuna? You seem to have some knowledge of how the sausage gets made, so you probably have heard of the APA, and its ilk, and thus know what Fed types can and cannot discoss.

Also, I’m pretty sure it’s the same as the Nautical Almanac, i.e. 1981, not 1983.

The “E” is the Easiest thing to outsource to testing companies that can easily proctor tests. And it would allow even more “E” places around the country for mariners to test at.

Not as easy as you seem to think it is. Scroll up a few posts and you’ll see one of the big issues that commercial 3rd party testing centers may not be able to accommodate. And the fees you pay for testing at an REC have not been changed for over 25 years, they may not be commensurate with the current cost of the service.

Let’s not forget there were no user fees whatsoever as late as the early 1980’s. The nautical almanac is forever frozen in 1981. The tides and currents stopped their perpetual motion in 1983, and the charts were last updated in 1990 or so.

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So reading the policy letter above am I to understand that if I fall under section 5 paragraph C, specifically having served as Master/Mate on a towing vessel (ATB) under 1600 GT, that I shouldn’t have to provide documentation of relevant service on a vessel equipped with Radar? The way it reads to me is that if you were the Master or Mate that you are deemed to have radar experience and paragraph C is saying that if you served in a position like say DP operator, that you would then need documentation? I’m thinking that I will still talk to the office and see if they can update our sea service letters to say that all of our vessels are equipped with radars. I was just looking for clarification. If I’m reading that wrong and they only go by tonnage of the vessel I would still need the renewal course or prove that I use a radar regularly. And paragraph J says after July 22, 2024 anyone serving as Master/Mate on a towing vessel over 26ft with a radar or a vessel over 300 GT must hold an endorsement of Radar Observer. I was under the impression that if you were on a commercial vessel that was equipped with a radar that you had to have the endorsement.

You’re not reading it correctly. If you served as Master or Mate on one of the vessels in paragraph 5B you do not pseicifically need to document radar usage. Those vessels are, without exception, required to have radar and obviously a mate or master uses it. Towing vessels (including ATBs) are NOT listed in paragraph 5B as there are provisions to give waivers of the requirement to have a radar (i.e. not all towing vessels have radar). Paragraph 5 C is for all other vessels not listed in 5C, including towing vessels. So if your service is on a towing vessel, you need to provide the evidence of radar usage.

This was a change in the rule. In the past, you did need to have the radar observer endorsement in your MMC. Now, and until June 22, 2024, you don’t need the endorsement in your MMC, but if you don’t have it in your MMC, you must have a certificate from a radar course immediately available (i.e. you have to qualify for the endorsement). In the past, the course certificate was to prove the endorsement in your MMC was up to date. Until 2024, the certificate will prove you are qualified to be a radar observer. Note that if you have the radar observer endorsement in your MMC, you do NOT need to have available a course certificate.

@jdcavo So would a sea service letter from the company stating that Masters and Mates use an ARPA Radar on a daily basis while onboard be sufficient evidence or is their some other way to document that your vessel has a radar and that we are proficient in its use? We also would have to prove at least once that we have had a qualifying ARPA course as well right and if I’m not mistaken that’s a negative endorsement. One that is only printed on the MMC if you don’t have ARPA? I took the course and it used to be listed on my license and it was taken off years ago when I upgraded to Master and I was told something to that effect.

To ensure it’s effective, the letter should (if true) state that the vessel is equipped with radar and use the magic words of the requirement in 46 CFR 10.232(a)(2)((vii) and 46 CFR 11.480(g): “…routinely uses radar for navigation and collision avoidance purposes.”

Radar observer is a national endorsement. ARPA is part of STCW requirements for Master, Chief Mate, and Officer in Charge of a Navigational Watch, but STCW allows for a limitation to vessels without ARPA if you don’t meet the competency and “knowledge, understanding, and proficiency” applicable to ARPA (the same applies ECDIS). It’s often called a “negative endorsement” but I prefer to call it what it is, a limitation. The language in the STCW Code (Table A-II/1) is
Training and assessment in the use of ARPA is not required for those who serve exclusively on ships not fitted with ARPA. This limitation shall be reflected in the endorsement issued to the seafarer concerned.
So, for STCW endorsements for Master, Chief Mate, and OICNW, if you do not have the “not valid on vessels equipped with ARPA” limitation next to your STCW endorsement, you are good for vessels with ARPA.

I submitted my renewal March 2nd to New York REC. March 17th it was sent to NMC. April 1st I was notified the doctor missed a signature (even after she and I both looked it over 20 times). I emailed the signed form back April 5th and they sent my Medical Certificate out April 8th, received it a couple days later. I have been “Ready to be evaluated PQEB” since April 8th. It’s a pretty straight forward renewal, I’m assuming they cut their staff back or are teleworking. Who knows, but this is the longest I’ve waited with them in the last 12 years. It’s been over 2 months, and I’m not even assigned to an evaluator.

Asking for a friend here, does anyone know what is the current regulation regarding MMC renewals for folks with MMCs about to expire and cannot get their Medical Certificate due to the lockdown or being locked-down?

Without the MMC lapsing, are there any options such as asking for an extension during this Pandemic and these abnormal circumstances?

Thanks in advance.