I don’t know if it would fly today, but…
When I was a lot younger and already had a 6-pack license my employer wrote or rather I wrote and he signed a letter on company letterhead that stated that whilst in his employ I served as captain on various vessels in the charter fleet, having tonnages between 5 and 35 tons in the waters of … Separated inland and ocean (NC) time and it worked. It was dressed up a bit but that is the basis.
Note that the time count was genuine and I already had a license so my time was often with passengers.
Just send your questions to the USCG office. I’ve spoken with Anthony Lloyd (head of the licensing and credential program) personally and he recommends you use the IASKNMC@USCG.MIL.
Thats where I get all my questions answered.
These are the folks that will ultimately help you get want you need. And don’t worry, they don’t bite! They will not hold any of your questions against you.
They are actively trying to improve their image one question at a time and I’m helping to spread that image!
Best of luck getting your license.
J. Crawford