[QUOTE=jdcavo;48767]46 CFR 11.201©[/QUOTE]
That only says: an applicant must have 3 months (90 days) within three years. [B] © An applicant for an officer endorsement must have at least three months of qualifying service on vessels of appropriate tonnage or horsepower within the three years immediately preceding the date of application.[/B]
Here is the whole cite:
[I]The minimum service required to qualify an applicant for an endorsement as master of ocean or near coastal steam or motor vessels of not more than 500 gross tons is:[/I]
[I] (a) Three years total service on ocean or near coastal waters. Service on Great Lakes and inland waters may substitute for up to 18 months of the required service. Two years of the required service must have been as a master, mate, or equivalent supervisory position while holding a license or MMC endorsement as master, mate, or operator of uninspected passenger vessels. One year of the required service as master, mate, or equivalent supervisory position must have been on vessels of over 50 gross tons.[/I]
Where does it say that there is a tonnage requirement that must be within the window? In the 500 ton qualifying service paragraph there are three separate types of service needed. One is aggregate amount of time. The second is amount of time on vessels as while in a position of authority. And the third part is you must actually be on a vessel of a certain tonnage for ‘some’ part of the time. The There must be ‘some’ seatime over a tonnage limit. Some seatime of so many days, and some as operator. But where does it say that 90 days within the last 3 years must be on a certain size vessel? It doesn’t. This sounds like an overzealous interpretation of the regs from an incomplete reading of the CFR The CFR says 3 months of seatime within 3 years. Where does it say: ‘which part of the required seatime must be within the ‘window’?’ The ‘appropriate tonnage’ caveat is part over 50 tons, and part of ANY tons. Where is the Navic regarding this? That should be interesting at the least, and arguable at best.